www.cops.usdoj.gov

2016 COPS Office Community Policing 

Development (CPD) Program

Award Owner’s Manual

U.S. Department of Justice, Office of Community Oriented Policing Services
2016 COPS Office Community Policing Development (CPD) Program Award Owner’s Manual

i 

2016 COPS Office Community Policing Development

(CPD) Program Award Owner’s Manual

This manual was created to assist COPS Office Community Policing Development (CPD) program recipients with 

the administrative and financial matters associated with the award.

For more information about your CPD award, please contact your COPS Office Program Manager. If you do not 

know the name or telephone number of your COPS Office Program Manager, please contact the COPS Office

Response Center at 800-421-6770.

U.S. Department of Justice

Office of Community Oriented Policing Services

145 N Street NE

Washington, DC 20530

Visit the COPS Office online: www.cops.usdoj.gov

Published September 2016
2016 COPS Office Community Policing Development (CPD) Program Award Owner’s Manual

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Contents

Getting Started ........................................................................................................................................................................... 1

I. Award Acceptance, Terms, and Conditions .................................................................................................................. 2

The award document .......................................................................................................................................................... 2

Award terms and conditions ............................................................................................................................................ 3

What are the specific rules regarding termination of award funding? .......................................................... 35

Accepting the award ........................................................................................................................................................ 36

Who should sign the award document for our agency? ..................................................................................... 36

By when must the award document be signed? .................................................................................................... 36

II. The Cooperative Agreement .......................................................................................................................................... 37

III. Procurement Process ....................................................................................................................................................... 48

IV. Accessing Award Funds .................................................................................................................................................. 49

Payment method ............................................................................................................................................................... 49

Setting up your account .................................................................................................................................................. 49

Additional payment questions ..................................................................................................................................... 51

V. Financial Record Maintenance ...................................................................................................................................... 53

Accounting systems and records ................................................................................................................................. 53

VI. Federal Audit Requirements ......................................................................................................................................... 55

Single Audit Act (SAA) requirements .......................................................................................................................... 55

Office of Inspector General (OIG) recipient audits ................................................................................................. 56

Typical audit findings ....................................................................................................................................................... 57

VII. Reports ................................................................................................................................................................................ 58

Federal Financial Reports ................................................................................................................................................ 58

Program Progress Reports .............................................................................................................................................. 59

Contact points to obtain technical assistance and report violations .............................................................. 61
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VIII. When the Award Period Has Ended ......................................................................................................................... 62

Final Federal Financial Report (SF-425) ...................................................................................................................... 62

Final Program Progress (Closeout) Report................................................................................................................ 62

IX. Conclusion ........................................................................................................................................................................... 64

Appendices ............................................................................................................................................................................... 65

Appendix A. List of source documents ...................................................................................................................... 65

Appendix B. Assurances and Certifications .............................................................................................................. 66

Appendix C. Community policing defined ............................................................................................................... 74

Appendix D. Sole source justification facts .............................................................................................................. 81

Appendix E. Conference reporting requirements .................................................................................................. 84

Appendix F. Consultant/contractor rate information sheet ............................................................................... 98

Appendix G. Whistleblower protection (41 U.S.C. 4712) ................................................................................... 100

Appendix H. 2 CFR Appendix II to Part 200: Contract provisions for

nonfederal entity contracts under federal awards ................................................................... 104

Appendix I. Remittance of Interest Earned Amounts ......................................................................................... 106

Glossary of Terms .................................................................................................................................................................. 107
2016 COPS Office Community Policing Development (CPD) Program Award Owner’s Manual

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Getting Started

Congratulations on receiving an award from the U.S. Department of Justice (DOJ), Office of Community Oriented 

Policing Services (COPS Office). The COPS Office Community Policing Development (CPD) Program awards 

provide funding to advance the practice of community policing in law enforcement agencies through 

educational resource products and services such as training and technical assistance, the development of 

innovative community policing strategies, applied research, guidebooks, and best practice documents. 

According to the COPS Office, community policing is a philosophy that promotes organizational strategies that 

support the systematic use of partnerships and problem-solving techniques to proactively address the 

immediate conditions that give rise to public safety issues such as crime, social disorder, and fear of crime. For a 

complete definition, please see appendix C, “Community policing defined,” on page 74. 

This CPD Award Owner’s Manual will assist your agency with the administrative and financial matters associated 

with your award. It was developed to ensure that all CPD award recipients are able to clearly understand and 

meet the requirements of their award. Please review this manual carefully because failure to follow award 

requirements can have serious ramifications. Please do not hesitate to call your COPS Office Program Manager as 

listed in your agency’s award package or the COPS Office Response Center at 800-421-6770 if you need 

assistance with the implementation of your award. 

When your agency applied for CPD funding, your agency was required to certify compliance with all applicable 

federal laws. In that regard, members of Congress have asked the Department of Justice to examine whether 

jurisdictions with “sanctuary policies” (i.e., policies that either prevent law enforcement from releasing persons 

without lawful immigration status into federal custody for deportation or policies that prevent state or local law 

enforcement from sharing certain information with Department of Homeland Security (DHS) officials), are in 

violation of 8 U.S.C. section 1373. For that reason, all recipients for this program should understand that if the 

COPS Office receives information which indicates that a recipient may be in violation of 8 U.S.C. section 1373 (or 

any other applicable federal law) that recipient may be referred to the DOJ Office of the Inspector General (OIG) 

for investigation. If the recipient is found to be in violation of an applicable federal law by the OIG, the recipient 

may be subject to criminal and civil penalties, in addition to relevant DOJ programmatic penalties including 

suspension or termination of funds, inclusion on the high risk list, repayment of funds, or suspension and 

debarment.

Thank you for providing us with the opportunity to work in partnership with you on this important project.
2016 COPS Office Community Policing Development (CPD) Program Award Owner’s Manual

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I. Award Acceptance, Terms, and Conditions

To officially accept and begin your COPS Office CPD Program award, your agency must access 

https://portal.cops.usdoj.gov, log in, review, and electronically sign the award document with the award terms 

and conditions; the financial clearance memorandum and, if applicable, the cooperative agreement that is 

incorporated by reference into the award document; and, if applicable, the special award conditions or high risk 

conditions in the award document supplement within 90 days of the date shown on the award congratulatory 

letter. 

Your agency will not be able to draw down award funds until the COPS Office receives your signed award 

document. For more information on drawing down award funds, please see section IV, “Accessing Award Funds,” 

on page 49 of this manual. 

The award document

The award document is the document indicating your official award funding amount, the award number, the 

award terms and conditions, and the award start and end dates. Please note that if your award includes a 

cooperative agreement, it is incorporated by reference into the award document and that by signing the award 

document, your agency has entered into the cooperative agreement with the COPS Office and agrees to abide 

by all the requirements in the cooperative agreement.

The award document is preprinted with your agency’s law enforcement and government executives’ names and 

addresses. For non-law enforcement agencies (institutions of higher education, private organizations, etc.), the 

authorized officials are the programmatic and financial officials who have the ultimate signatory authority to 

sign contracts on behalf of your organization. If this information is incorrect or has changed, please update your 

“Agency Contacts” online at https://portal.cops.usdoj.gov through the “Account Access” link. If the law 

enforcement or government official has changed since the time of application, please have the current law 

enforcement executive or government executive for your agency sign the award document. Be sure to 

familiarize yourself with all terms, conditions, and requirements of your award before signing the award 

document. To officially accept your award, please electronically sign the award document within 90 days of the 

date shown on the award congratulatory letter. Print and retain a copy of all pages of the award document, 

award terms and conditions, the Financial Clearance Memorandum (FCM), and, if applicable, the cooperative 

agreement and the award document supplement for your records.

The award start date indicated on the award document means that your agency may be reimbursed for any 

allowable costs incurred on or after this date. The duration of your CPD award is listed on your award document.

Your award number is in the following format: 2016-XX-XX-XXXX for Fiscal Year (FY) 2016 awards. The COPS 

Office tracks award information based upon this number. Therefore, it is important to have your agency’s award 

number (or your agency’s ORI number) readily available when corresponding with the COPS Office. 

Your originating agency identifier (ORI) number begins with your state abbreviation followed by five numbers or 

letters (e.g., VA00000). This number is assigned by the Federal Bureau of Investigation (FBI) for use in tracking 

information for the Uniform Crime Report (UCR). The COPS Office tracks programmatic award information based 

upon this ORI number. If your agency does not have an ORI number assigned by the FBI, the COPS Office assigns 
2016 COPS Office Community Policing Development (CPD) Program Award Owner’s Manual

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a non-official ORI code to use as an agency identifier (in such cases, the last two characters will be “ZZ”). If you 

have any questions regarding your award, please refer to your award number or your agency’s ORI number 

when corresponding with the COPS Office. 

Your OJP vendor number, in most circumstances, is your agency’s nine- or thirteen-digit federal tax identification 

number assigned to you by the Internal Revenue Service (IRS). If your OJP vendor number differs from your tax 

identification number, the OJP vendor number is only to be used for administrative purposes in connection with 

this award program, and should not be used for IRS purposes.

Award terms and conditions 

The award terms and conditions are listed on your agency’s award document. By accepting this award, you are 

obtaining federal funds from the COPS Office. As part of that agreement, your agency acknowledges that it will 

comply with these terms and conditions (and, if applicable, any additional special or high risk conditions specific 

to your agency). The section that follows describes, in detail, all of the award conditions, their rationales, and 

their implications. It also addresses many frequently asked questions. If you have additional questions 

concerning any of these award conditions, please contact your COPS Office Program Manager or call the COPS 

Office Response Center at 800-421-6770.

In limited circumstances, your award may be subject to special conditions that prevent your agency from 

drawing down or accessing award funds until the special conditions are satisfied as determined by the COPS 

Office. Any special or high risk conditions will be included in the award document supplement. However, if you 

have questions about the special or high risk conditions, please contact your assigned COPS Office Program 

Manager. 

Reasons for award terms and conditions 

The requirements of your CPD award are established within

• the Public Safety Partnership and Community Policing Act of 1994, which established the COPS Office; 

• the applicable rules, regulations and policies issued by the U.S. Department of Justice, Office of 

Management and Budget (OMB), the Government Accountability Office (GAO), and the United States 

Treasury; 

• the specific CPD requirements established by the COPS Office. 

A list of source documents for this booklet is provided in appendix A on page 65. You may request copies of any 

source reference document from:

Office of Administration, Publication Unit

New Executive Office Building

725 17th Street NW, Room G 236

Washington, DC 20503

COPS Office-specific documents may be requested directly from the COPS Office by calling your COPS Office

Program Manager. 
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Review of award terms and conditions 

By signing the award document to accept this CPD award, your agency agrees to abide by the following award 

terms and conditions:

1. Award Owner’s Manual

Condition:

The recipient agrees to comply with the terms and conditions in the 2016 CPD Program Award Owner's Manual; COPS 

Office statute (42 U.S.C. §. 3796dd, et seq.); the requirements of 2 C.F.R. Part 200 (Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted by the U.S. Department of 

Justice in 2 C.F.R. § 2800.101; 48 C.F.R. Part 31 (FAR Part 31) as applicable (Contract Cost Principles and Procedures); 

representations made in the CPD award application; and all other applicable program requirements, laws, orders, 

regulations, or circulars.

Why this condition:

This manual has been designed to inform you of the requirements, laws, regulations, and policies that apply to 

your award. Your agency will be responsible for the information and rules contained in this manual and for 

implementing your award in compliance with the applicable terms, conditions, and regulations. Please note that 

in accordance with 200 C.F.R. § 200.101(c), the COPS Office applies 2 C.F.R. Subparts A through E to for-profit (or 

commercial) entities. More detailed guidance regarding any particular award requirement or your agency’s 

specific circumstances can be requested through your COPS Office Program Manager. 

What you should do:

Please read the entire CPD Award Owner’s Manual carefully prior to signing the award document. If you have 

any questions, please contact your COPS Office Program Manager. When accepting your award, you should 

ensure that the proper reporting and financial systems are in place to satisfy the award requirements.

2. Assurances and Certifications

Condition:

The recipient acknowledges its agreement to comply with the Assurances and Certifications forms that were signed as 

part of its CPD application.

Why this condition:

Although the COPS Office has made every effort to simplify the process of applying for and receiving awards, 

several provisions of federal law require us to obtain the recipient’s Assurances and Certifications regarding 

certain matters. Most of the Assurances and Certifications apply to all federal award programs.

What you should do:

Applicants to COPS Office award programs are required to sign the Assurances and Certifications forms at the 

time of application. Signing these documents assures the COPS Office that you have read, understood, and 

accepted the award terms and conditions outlined in the Assurances and Certifications. Please read these 

documents carefully, because signatures on these documents are treated as a material representation of fact 
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upon which reliance will be placed when the U.S. Department of Justice determines whether to fund the 

covered award. Additional copies of the Assurances and Certifications forms are contained in appendix B on 

page 66 of this manual. If you have any questions about them, please contact your assigned COPS Office

Program Manager via the COPS Office Response Center at 800-421-6770.

3. Allowable Costs

Condition:

The funding under this project is for the payment of approved costs for Community Policing Development purposes. 

The allowable costs for which your agency’s award has been approved are limited to those listed on the Financial 

Clearance Memorandum, which is included in your agency’s award package. The Financial Clearance Memorandum 

specifies the costs that your agency is allowed to fund with your Community Policing Development award. It also 

describes any costs which have been disallowed after review of your proposed budget. The recipient may not earn or 

keep any profit resulting from this award unless expressly authorized in writing by the COPS Office. Your agency may 

not use Community Policing Development award funds for any costs that are not identified as allowable in the 

Financial Clearance Memorandum.

Why this condition:

CPD funding may only be used to pay for items and services approved by the COPS Office as reflected in the 

Financial Clearance Memorandum (FCM). 2016 CPD funds must be used to advance the practice of community 

policing in law enforcement agencies through the development of educational resource products and services 

such as training and technical assistance, the development of innovative community policing strategies, applied 

research, guidebooks, or best practice documents that are national in scope. 

Please note that in accordance with 2 C.F.R. § 200.101(c), the COPS Office applies the cost principles set forth in 2 

C.F.R. Subpart E to for-profit (or commercial) entities instead of the Federal Acquisition Regulation (FAR) at 48 

C.F.R. Subpart 31.2. In addition, in accordance with 2 C.F.R. § 200.400(g), the recipient may not earn or keep profit 

as a result of this award unless expressly authorized by the specific terms and conditions of your award.

To be eligible for payment under this award, the purchase of approved items must be made on or after the 

award start date and comply with the guidelines described in section IV, “Accessing Award Funds,” on page 49 of 

this manual. Section V, “Financial Record Maintenance,” on page 53, outlines the types of records you must keep 

to document that you followed this award condition. Purchases must also reflect the costs that were approved in 

the FCM.

What you should do:

Refer to your FCM for the list of approved allowable cost categories. Listed below are the budget categories that 

may appear on your FCM. If your agency’s operating budget categories differ from those approved in the FCM, 

your agency should maintain a cross-reference to clearly identify where the funds were budgeted. As long as 

funds are spent during the award period on project costs that were documented in your application’s budget 

summary and approved by the COPS Office through the issuance of the FCM, this award condition will be 

satisfied. The award number should be indicated on all budgetary documentation including purchase orders, 

receipts, and other documentation. All recipients should keep and maintain the most recent, approved version 

of their 2016 CPD application for future reference.
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Personnel (salaries and benefits)

Personnel expenses may be reimbursed for project activities that take place on or after the award start date. In 

addition, a position’s salary must be reasonable for the services rendered and must be paid to a person 

appointed under the law or rules governing hiring by your agency. Salary payments must be based on payroll 

records. Time and attendance records or the equivalent must support payroll records. 

For recipients that are state, local, or tribal government entities, award-funded salary and benefit costs must 

supplement, not supplant (replace), locally funded personnel costs that would have been funded even in the 

absence of this award. If any civilian personnel are employed on a part-time or temporary basis, your agency 

must specify the percentage of time that each person is working solely on the project identified in your agency’s 

CPD proposal.

Fringe benefits may be paid if they are part of a reasonable compensation package offered to your employees. 

Particular items of fringe benefits must fall within the categories authorized by the COPS Office. Authorized 

fringe benefits include FICA, Social Security, health insurance, life insurance, vacation, sick leave, retirement, 

worker’s compensation, and unemployment insurance.

Equipment/Technology 

To be eligible for payment under this award, the purchase of equipment and technology must occur on or after 

the award start date, the items must be those specifically applied for and approved by the COPS Office, and they 

must meet the guidelines described in 2 C.F.R. Part 200 (Uniform Administrative Requirements, Cost Principles, 

and Audit Requirements for Federal Awards) as adopted by the U.S. Department of Justice in 2 C.F.R. Part

§2800.101. For recipients that are state, local, or tribal government entities, award-funded equipment and 

technology must supplement, not supplant (replace), locally funded items that would have been funded even in 

the absence of this award. Funds currently budgeted or obligated for the purchase of equipment and 

technology may not be reallocated to other purposes or reimbursed upon receiving the CPD award. Agencies 

should establish practices to receive, label, inventory and track the location of all purchases made for awardfunded equipment and/or technology. 

Supplies

All supplies must be solely used for the project identified in your project proposal. Reimbursements for office 

supplies that are consumed by routine administrative purposes instead of project-related activities are 

prohibited. Items must meet the guidelines described in 2 C.F.R. Part 200 (Uniform Administrative Requirements, 

Cost Principles, and Audit Requirements for Federal Awards) as adopted by the U.S. Department of Justice in 2 

C.F.R. Part §2800.101. 

Travel/Training

Travel costs for transportation, lodging, subsistence, temporary dependent care, and related items are allowable 

under the CPD program with prior approval from the COPS Office. In accordance with 2 C.F.R. § 200.474, travel 

costs for official business directly related to the award will be reimbursed based upon the recipient’s written 

travel reimbursement policies if the costs are reasonable and allocable under the project. In the absence of an 

acceptable written policy regarding travel costs, allowable rates and amounts established by the U.S. General 

Services Administration (GSA) for the relevant geographic area will apply. The current GSA travel policy and per 

diem rates can be found at www.gsa.gov. 
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Allowable airfare costs will be reimbursed based upon the least expensive unrestricted accommodations class 

offered by commercial airlines—for example, lowest discount commercial airfare, the Federal Government

contract airfare (if authorized and available), or standard coach airfare—unless otherwise authorized in advance 

by the COPS Office. 

Temporary dependent care costs above and beyond regular dependent care that directly results from 

conference travels are allowable as long as the costs incurred (1) are a direct result of the individual’s travel for 

the federal award; (2) are consistent with the recipient’s documented travel policy for all entity travel; and (3) are 

only temporary during the travel period.

The CPD program will fund award-related travel costs for the recipient agency or other (nonrecipient) individuals 

to attend training and technical assistance conferences, seminars, or classes or to visit a site specified in the 

application. Allowable award-related travel costs that were included in the application have been approved by 

the COPS Office as part of the CPD award and final budget. Your agency should keep timely and accurate records 

of all travel expenses. If at any time these costs change, you should immediately contact your COPS Office

Program Manager. 

Contracts/Consultants

Compensation for individual consultant services procured under a COPS Office award must be reasonable, 

allocable in accordance with 2 C.F.R. Subpart E—Cost Principles, and consistent with rates paid for similar 

services in the marketplace. Unless otherwise approved by the COPS Office, consultant rates will be based on the 

salary a consultant receives from his or her primary employer, as applicable, up to $650 per day. For consultant 

or contractor rates which exceed $650 per day, the COPS Office requires written justification if the consultants or 

contractors are hired through a noncompetitive bidding process, and recipients must receive COPS Office

approval of those rates before drawing down award funds. Determinations of approval will be made on a caseby-case basis.

Other costs 

Project-related expenditures that do not conform to any of the category descriptions specified above are

included in the “other costs” section of your FCM. In addition, items that have a direct correlation to the overall 

success of a recipient’s project objectives and are necessary for the project to reach full implementation will be 

considered on a case-by-case basis by the COPS Office. 

For recipients that are state, local, or tribal government entities, requests may be made only for items or 

positions that are not otherwise budgeted with state, local, or Bureau of Indian Affairs (BIA) funds and would not 

be funded in the absence of the CPD award.

If at any time you are unsure if an item is considered allowable or unallowable, please contact your COPS Office

Program Manager for further assistance.

Indirect costs

Indirect (facilities and administrative, or F&A) costs are costs incurred for a common or joint purpose that are not 

readily assignable to a particular project but are necessary to the operation of the agency and the performance 

of the project. Indirect costs are allowable for this program, but must adhere to the standards set forth in the 

applicable Office of Management and Budget (OMB) guidance as stated in 2 C.F.R. Part 200 (Uniform 
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Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted by the

U.S. Department of Justice in 2 C.F.R. § 2800.101. Examples of indirect costs include those incurred for facility 

operation and maintenance, depreciation, and administrative salaries. 

Indirect cost rates are federally negotiated and approved rates that are based on audited and documented 

expenses approved to be included within an indirect cost rate. It is important that your agency carefully track 

and update its indirect cost rate during the COPS Office award period.

The recipient understands that if it submitted an expired indirect cost rate agreement at the time of application, 

it will be unable to recover federal funds for indirect costs until the COPS Office receives a current indirect cost 

rate agreement covering the award period. A special condition may be added to the award prohibiting the 

obligation, expenditure, or drawdown of funds for reimbursement for indirect costs until a current indirect cost 

rate has been approved by your cognizant federal agency and submitted to the COPS Office.

If your agency’s approved indirect cost rate expires during the award period, a current approved rate must be 

submitted to the COPS Office in order to continue to draw down award funding for indirect costs. Your expired 

rate must be renegotiated or extended by your cognizant federal agency. An approved indirect cost rate may be 

extended one time for up to four years, and once the cognizant federal agency has approved your extension, 

you must abide by that rate for the agreed-upon time period. At the end of the extension period, you must 

renegotiate a new indirect cost rate. Your agency must advise the COPS Office in writing of any changes to your 

approved indirect cost rate during the award period and must request a budget modification with the COPS 

Office to reflect any rate change.

If your agency has never received a negotiated indirect cost rate, then you may request a de minimis indirect 

cost rate of 10 percent of modified total direct costs (MTDC). See 2 C.F.R. § 200.414(f).

In addition, if a provisional indirect cost rate is in effect at award closeout, your agency shall proceed with 

closeout, but you will need to complete an expenditure analysis upon receipt of the approved final indirect cost 

rate to determine if an adjustment is necessary. If your agency drew down excess COPS Office funding for 

indirect costs, then your agency must return the overpayment to the COPS Office and submit a revised Federal 

Financial Report (SF-425). If your agency incurred additional indirect costs, then your agency may request a 

budget modification if the award is still open and award funds are available. If your agency returns or draws 

down COPS Office funding, then your agency will need to submit a revised final Federal Financial Report (SF425).

Please be advised that recipients may not use COPS Office funding for the same item or service also funded by another 

U.S. Department of Justice award. 

See also award condition #13 on page 16, “Duplicative Funding.”

4. Supplementing, Not Supplanting

Condition:

State, local, and tribal government recipients must use Community Policing Development funds to supplement, and 

not supplant, state, local, or Bureau of Indian Affairs (BIA) funds that are already committed or otherwise would have 

been committed for award purposes (hiring, training, purchases, and/or activities) during the award period. In other 
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words, state, local, and tribal government recipients may not use COPS Office funds to supplant (replace) state, local, 

or BIA funds that would have been dedicated to the COPS Office-funded item(s) in the absence of the COPS Office 

award.

Why this condition:

The COPS Office statutory nonsupplanting requirement mandates that award funds not be used to replace state 

or local funds (or, for tribal recipients, BIA funds) that would, in the absence of federal aid, be made available for 

the award purposes.

What you should do:

For state, local, and tribal recipients, CPD funds may not be used to pay for any item or cost funded under the 

award (equipment, personnel, training, etc.) if that item or cost was otherwise budgeted with state, local, or BIA 

funds. In addition, recipients may not reallocate state, local, or BIA funds from one area within the law 

enforcement budget to another as a result of receiving CPD award funds. If you have questions concerning this 

award term and how it pertains to your project budget, please contact your COPS Office Program Manager. 

5. Extensions

Condition:

Your agency may request an extension of the award period to receive additional time to implement your award 

program. Such extensions do not provide additional funding. Only those recipients that can provide a reasonable 

justification for delays will be granted no-cost extensions. Extension requests must be received prior to the end date of 

the award.

Why this condition:

Under federal regulations, requests to extend the award period require prior written approval from the COPS 

Office. Without an approved extension, your agency is not permitted to draw down federal funding for costs 

incurred beyond the official award end date. When justified, the COPS Office will seek to accommodate 

reasonable requests for no-cost time extensions to fully implement the COPS Office award.

What you should do:

The COPS Office will contact your agency during the last quarter of the award period to determine whether a nocost time extension is needed. Requests to extend the award period must be received by the COPS Office before 

the official award end date. Failure to submit a request for a no-cost time extension before the award end date 

may result in the immediate deobligation of any remaining award funds. 

Please note that the project period of performance will be extended, if necessary, until the deliverable is 

considered final. If the award is set to expire, prior to the final approval of the deliverable, a no-cost extension 

will be executed for a reasonable amount of time for the recipient to complete the final deliverable. 
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6. Modifications

Condition:

Award modifications under the Community Policing Development program are evaluated on a case-by-case basis in 

accordance with 2 C.F.R. § 200.308. For federal awards in excess of $150,000, any modification request involving the 

reallocation of funding between budget categories that exceed or are expected to exceed 10 percent (10%) of the total 

approved budget requires prior written approval by the COPS Office. Regardless of the federal award amount or 

budget modification percentage, any reallocation of funding is limited to approved budget categories. In addition, 

any budget modification that changes the scope of the project requires prior written approval by the COPS Office.

Why this condition:

The COPS Office realizes that agencies may need to reprogram award funds. Acceptable examples of such award 

modifications include purchasing additional equipment using cost-savings from approved items or purchasing a 

different type of equipment due to changing needs. Under federal regulations, you are required to expend 

federal funds only as approved in the FCM. Requests to change or alter an award that meet certain threshold

requirements must be submitted to the COPS Office for written approval, prior to their purchase or 

implementation. Without prior written approval, you must continue to implement your award as it was originally 

outlined and accepted by your agency. Reprogrammed funds must be allocated for items covered within the 

original scope of the award. Please be advised that reprogramming requests for unallowable costs will not be 

approved. 

Your agency may reprogram its budget up to an aggregate (over the course of your project) of 10 percent of the 

total project cost without prior written approval from the COPS Office. However, you should notify your COPS 

Office Program Manager of any reprogramming that falls below the 10 percent threshold as well. For awards in 

excess of $150,000, any reprogramming of funds that totals an aggregate of 10 percent or more of the approved 

budget requires prior written approval from the COPS Office. 

What you should do:

You are required to notify your COPS Office Program Manager if you determine that your agency will need to 

reprogram award funds. If your modification exceeds an aggregated (over the course of your project) 10 percent 

of your overall award, your agency must access https://portal.cops.usdoj.gov and select the “Account Access” 

link in the upper right corner to log in and submit your request to the COPS Office, providing the proposed 

changes, details of why the change is needed, etc.

Please contact your COPS Office Program Manager for further direction on any additional requirements that may 

apply to your modification request. The COPS Office will then evaluate your request and notify your agency of 

our decision in writing. Implementation of the modified award budget may begin following written approval 

from the COPS Office. Please note that modification approvals for active awards will be accompanied by a 

modified FCM reflecting the approved changes. 

7. Evaluations

Condition:

The COPS Office may conduct monitoring or sponsor national evaluations of the CPD Program. The recipient agrees to 

cooperate with the monitors and evaluators.
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Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 states that evaluations of the program may 

be carried out or commissioned by the attorney general for the furtherance of the purposes of the act. The COPS 

Office conducts evaluations to determine which programs are working, how programs may be improved, and 

why certain programs are more successful than others. Specifically, the COPS Office may assess the way in which 

your agency implements its CPD award. COPS Office staff or evaluators may study the effectiveness of funded 

programs, projects, and activities. Evaluators may collect information about the programs’ effect on crime, 

victims of crime, and the quality of life in communities. In addition, they may ask questions about the challenges 

encountered during project implementation, how residents feel about community policing, and how police feel 

about their work. This information will be useful to other communities and police agencies across the country.

What you should do:

When evaluations are undertaken, you may be contacted in writing with specific requests for information. In 

general, evaluators may need to speak with individuals in your agency or department, observe activities, and 

obtain written reports about and from your agency or department. You will be asked to facilitate any site visits 

and information-gathering activities. In addition, you will be asked to provide accurate and timely information 

about your award activities. You should fully comply with any requests made regarding these evaluations.

8. Reports/Performance Goals

Condition:

To assist the COPS Office in monitoring and tracking the performance of your award, your agency will be responsible 

for submitting quarterly programmatic progress reports that describe project activities during the reporting period 

and quarterly Federal Financial Reports using Standard Form 425 (SF-425). The progress report is used to track your 

agency’s progress toward implementing community policing strategies and to collect data to gauge the effectiveness 

of increasing your agency’s community policing capacity through COPS Office funding.

Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 and other federal regulations and policies 

require that financial assistance provided by the Federal Government be monitored carefully to ensure the 

proper use of federal funds. In addition, the COPS Office seeks to document, on a continuing basis, the progress 

of our programs and recipients.

What you should do:

This award condition is designed to make your agency aware of reporting requirements associated with CPD 

awards. All reports should be submitted to the COPS Office within the deadlines given to avoid suspension or

possible termination of award funds or other remedial actions. Quarterly programmatic progress reports and a 

final programmatic closeout report must be submitted directly to the COPS Office through the “Account Access” 

link of the COPS Office website at https://portal.cops.usdoj.gov. Your agency is also required to submit 

quarterly Federal Financial Reports using Standard Form 425 (SF-425) within 30 days after the end of each 

calendar quarter.

For more information, please refer to section VII, “Reports,” on page 58 of this manual.
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9. Award Monitoring Activities

Condition:

Federal law requires that recipients receiving federal funding from the COPS Office must be monitored to ensure 

compliance with their award conditions and other applicable statutory regulations. The COPS Office is also interested 

in tracking the progress of our programs and the advancement of community policing. Both aspects of award 

implementation—compliance and programmatic benefits—are part of the monitoring process coordinated by the 

U.S. Department of Justice. Award monitoring activities conducted by the COPS Office include site visits, office-based 

grant reviews, alleged noncompliance reviews, financial and programmatic reporting, and audit resolution. As a CPD 

recipient, you agree to cooperate with and respond to any requests for information pertaining to your award.

Why this condition:

The Public Safety Partnership and Community Policing Act of 1994 states that each award program must contain 

a monitoring component. The COPS Office actively monitors how recipients are complying with COPS Office

award requirements. In addition, the monitoring component provides customer service and technical assistance 

to help ensure recipients understand how to remain in compliance while implementing their awards. 

What you should do:

Your agency may be required to accommodate routine and non-routine efforts by the COPS Office, or an entity 

designated by the COPS Office, to examine your agency’s use of federal funds both programmatically and 

financially. The four primary means of ensuring recipients’ compliance with the terms and conditions of their 

awards are as follows: 

1. Site visits. The COPS Office strategically selects award recipients based on a variety of risk factors to 

conduct site visits to ensure compliance with award terms and conditions. The purpose of site visits is threefold:

i. To review for compliance with the terms and conditions of the award

ii. To review the recipient’s community policing strategies

iii. To provide customer service and technical assistance

If selected, recipients will be notified in writing in advance with detailed instructions on how to prepare for 

the review of their COPS Office awards. The site visit is generally performed over a period of one or more 

days. Recipients will have an opportunity to resolve any identified noncompliance issues while on-site or if 

necessary, following the site visit. In addition, recipients will also have an opportunity to seek customer 

service and/or technical assistance on the implementation of their award. 

2. Enhanced Office-Based Grant Reviews (EOBGR). In lieu of a site visit, awards may be selected for an 

EOBGR conducted at the COPS Office via teleconference or video conference. EOBGRs serve as an alternative 

for conducting site visit reviews in support of the COPS Office’s overall award monitoring strategy. The 

purpose of the EOBGR is three-fold: 

i. To review for compliance with the terms and conditions of the award

ii. To review the recipient’s community policing strategies

iii. To provide customer service and technical assistance
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If selected, the recipient will be notified in writing in advance of any EOBGR of its COPS Office awards. This 

review is generally performed over a one- to two-day period. Compliance reviews will be conducted for 

active awards to address any noncompliance and/or administrative issues identified during the review. In 

addition, award recipients will receive customer service and/or technical assistance on the implementation 

of their award. 

3. Alleged Noncompliance Referral (ANCR). An ANCR is an allegation of suspected noncompliance that 

originates from an internal source within the COPS Office or an external referral from one of many sources. 

Internal ANCRs generally originate from COPS Office Grants Administration Division, COPS Office Finance 

Division, or the COPS Office Legal Division, although any COPS component may refer a noncompliance issue 

to the ANCR. External noncompliance referrals may be received from anonymous complainants, media, 

citizens, law enforcement agencies, other Federal agencies, or other outside sources. On a case-by-case 

basis, COPS ANCR staff members determine the appropriate course of action to take to investigate 

complaints of alleged noncompliance. This may include phone or letter contact or a site visit by COPS Office 

staff or the OIG. Each ANCR referral is resolved as a violation or non-violation based upon the supporting 

documentation and/or other factors used to make a determination for compliance or non-compliance.

4. Audit Liaison. The OIG may conduct a random audit for any recipient of a COPS Office award. In the event 

your agency has undergone an OIG audit and there are audit recommendations (findings) resulting from 

noncompliance and/or poor accountability practices, the COPS Office Audit Liaison Section will work with 

your agency to resolve and close these recommendations. Remedies to close recommendations may 

include repayment of award funds and/or providing adequate documentation to demonstrate compliance 

and/or providing proof of policies or procedures that were created or revised to directly address the causes 

for the noncompliance as a proactive preventative measure to avoid future noncompliance. 

Recipients are responsible for remedying any award noncompliance that is identified during site visits, EOBGRs, 

and/or ANCRs. In addition, recipients are responsible for remedying noncompliance stemming from audit 

recommendations identified in audits of COPS Office awards conducted by the OIG and the Office of the Chief 

Financial Officer (OCFO). Remedies for noncompliance may include but are not limited to repayment of award 

funds for unallowable or unsupported costs, providing adequate documentation to demonstrate compliance, 

suspending active award funding, voluntary withdrawal from or involuntary termination of remaining award

funds, or a restriction from receiving future COPS Office awards for a period of time. Under certain conditions, 

additional actions may include referral and placement on the U.S. Department of Justice’s High Risk List, which

will include mandatory completion of the Office of Justice Programs Financial Management Training and being

subject to increased monitoring of current and future awards while on the list. In the event of criminal misuse of 

award funds, recipients may also be subject to fines and imprisonment. To avoid findings of noncompliance, 

recipients are strongly encouraged to become familiar with the COPS Office Grant Monitoring Division’s Grant 

Monitoring Standards and Guidelines and Award Owner’s Manual for the year in which the award was made. 

Recipients should also contact their COPS Office Program Manager at any time during the life of a COPS Office

award with questions concerning award conditions, terms, or requirements to seek guidance to avoid 

noncompliance. It is necessary for recipients to maintain all relevant documentation (administrative, financial, 

and programmatic) used to develop the application and implement the award that may be necessary or 

required to demonstrate award compliance. For more information, please contact the COPS Office Response 

Center at 800-421-6770 or at AskCopsRC@usdoj.gov. 
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10. Federal Civil Rights Laws

Condition:

As a condition of receipt of federal financial assistance, you acknowledge and agree that you will not (and will require 

any subrecipients, contractors, successors, transferees, and assignees not to), on the grounds of race, color, religion, 

national origin (which includes providing limited English proficient persons meaningful access to your programs), sex, 

disability, or age, unlawfully exclude any person from participation in, deny the benefits of or employment to any 

person, or subject any person to discrimination in connection with any programs or activities funded in whole or in 

part with federal funds. These civil rights requirements are found in the nondiscrimination provisions of Title VI of the 

Civil Rights Act of 1964, as amended (42 U.S.C. § 2000d); the Omnibus Crime Control and Safe Streets Act of 1968, as 

amended (42 U.S.C. § 3789d); Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794); the Age 

Discrimination Act of 1975 (42 U.S.C. §6101, et seq.); Title IX of the Education Amendments of 1972, as amended (20 

U.S.C. § 1681, et seq.); and the corresponding DOJ regulations implementing those statutes at 28 C.F.R. Part 42 

(subparts C, D, E, G, and I). You also agree to comply with Executive Order 13279, as amended by Executive Order 

13559, and the implementing regulations at 28 C.F.R Part 38 Partnerships With Faith-Based and Other Neighborhood 

Organizations, which requires equal treatment of religious organizations in the funding process and 

nondiscrimination of beneficiaries by faith-based organizations on the basis of belief or nonbelief.

Why this condition:

In establishing financial assistance programs, Congress linked the receipt of federal funding to compliance with 

federal civil rights laws. As a result, recipients are required to comply with the civil rights requirements found in 

the nondiscrimination provisions referenced above. A hold may be placed on your award if it is deemed that 

your agency is not in compliance with federal civil rights laws or is not cooperating with an ongoing federal civil 

rights investigation. If a hold is placed on your award, you will not be able to obligate or draw down federal 

funds under your agency’s COPS Office award until you comply with federal civil rights laws or cooperate with 

any ongoing federal civil rights investigation.

What you should do:

Included with your award package is a memorandum from the Office for Civil Rights, Office of Justice Programs, 

and the U.S. Department of Justice, which addresses the federal civil rights statutes and regulations applicable to 

your award. You should review this memorandum to understand your agency’s civil rights responsibilities.

As a recipient of federal financial assistance from the COPS Office, you are required to comply with the 

applicable federal civil rights laws and to collect data and information sufficient to permit effective enforcement 

of such laws and to cooperate with any federal civil rights investigation, which includes providing access to 

records, accounts, documents, information, facilities, and staff. 

11. Equal Employment Opportunity Plan (EEOP)

Condition:

All recipients of funding from the COPS Office must comply with the federal regulations pertaining to the development 

and implementation of an Equal Employment Opportunity Plan (EEOP) (28 C.F.R. Part 42 subpart E).
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Why this condition:

It is the experience of the U.S. Department of Justice in implementing its responsibilities under the Omnibus 

Crime Control and Safe Streets Act of 1968 (Safe Streets Act), the statute that funds the COPS Office, that “the full 

and equal participation of women and minority individuals in employment opportunities in the criminal justice 

system is a necessary component to the Safe Streets Act’s program to reduce crime and delinquency in the 

United States” (28 C.F.R. § 42.301). EEOPs do not impose quotas or hiring requirements on recipients. 

What you should do:

The obligations to comply with the EEOP requirement differ depending on your organization’s legal status, the 

number of its employees, and the amount of the award.

If your organization is a government agency or private business and has received a single award for $500,000 or 

more and has fifty or more employees (counting both full- and part-time employees but excluding political 

appointees), then it must prepare a Utilization Report and submit it to the OCR for review within 90 days from 

the start date of the award. For assistance in developing a Utilization Report, please consult the OCR's website at 

www.ojp.usdoj.gov/about/ocr/eeop.htm and click Complying with the EEOP Requirement.

If your organization is a government agency or private business and the largest single award it has received is 

$25,000 or more but less than $500,000, and it has fifty or more employees (counting both full- and part-time 

employees but excluding political appointees), then it must prepare a Utilization Report, but it need not submit 

the report to the OCR for review. Instead, your organization must certify that it is exempt from the submission 

requirement, that it maintains the Utilization Report on file, and that it will make the Utilization Report available 

for review on request. For assistance in developing a Utilization Report, please consult the OCR's website at 

www.ojp.usdoj.gov/about/ocr/eeop.htm and click Complying with the EEOP Requirement.

If your organization has fewer than fifty employees or receives an award of less than $25,000 or is a nonprofit 

organization, a medical institution, an educational institution, or an Indian tribe, then it is exempt from the EEOP 

requirement. To claim the exemption, however, your organization must certify that it is exempt by logging onto 

the OCR website at www.ojp.usdoj.gov/about/ocr/eeop.htm and following the Certification Form instructions.

If you have further questions regarding the EEOP requirements, you may contact an EEOP specialist at the OCR 

by telephone at 202-307-0690, by TTY at 202-307-2027, or by e-mail at EEOsubmisson@usdoj.gov. 

12. False Statements

Condition:

False statements or claims made in connection with COPS Office awards may result in fines, imprisonment, or 

debarment from participating in federal awards or contracts, and/or any other remedy available by law.

Why this condition:

This condition advises recipients of the consequences of submitting false claims or statements on applications, 

financial and programmatic reports, or other award documents.
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What you should do:

Ensure that all documentation related to your agency’s receipt and use of award funding (award applications, 

progress reports, Federal Financial Reports, etc.) is true and accurate.

13. Duplicative Funding

Condition:

The recipient understands and agrees to notify the COPS Office if it receives, from any other source, funding for the 

same item or service also funded under this award.

Why this condition:

This award was made to your agency to address its law enforcement needs that are not funded with other funds, 

including federal, state, local, tribal, or BIA funds. Consequently, your agency may not use this funding for items 

or services that you already have funding for from other sources. 

What you should do:

If your agency receives funding from another source for the same item(s) or services(s) also funded under this 

award, please contact your COPS Office Program Manager or call the Response Center at 800-421-6770. If 

necessary, the COPS Office will work with your agency to reprogram funding for items or services that are 

allowable under this award program.

14. Additional High-Risk Recipient Requirements

Condition:

The recipient agrees to comply with any additional requirements that may be imposed during the award performance 

period if the awarding agency determines that the recipient is a high-risk recipient (Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. § 200.207 as adopted by the U.S. 

Department of Justice in 2 C.F.R. § 2800.101).

Why this condition:

In accordance with 2 C.F.R. § 200.207, the DOJ may impose additional requirements specific to your award, as 

needed, when it determines that there is unsatisfactory performance, financial or administrative instability, 

noncompliance with award terms and conditions, or other lack of responsibility risk factors. In such cases, the 

DOJ may impose special conditions or restrictions that may include requiring the production of documentation, 

financial award administration training, on-site monitoring, prior approval for expenditure of funds, quarterly 

progress reports, separate bank accounts, or other requirements.

What you should do:

In order to obtain a COPS Office award, recipients must agree to comply with any additional requirements that 

may be imposed during the award performance period if the awarding agency determines that the recipient is a 

high-risk recipient.
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15. System for Award Management (SAM) and Universal Identifier Requirements

Condition:

The Office of Management and Budget requires federal agencies to include the following standard award term in all 

awards and cooperative agreements made on or after October 1, 2010:

A. Requirement for System for Award Management (SAM)

Unless you are exempted from this requirement under 2 C.F.R. Part 25.110, you as the recipient must maintain 

the currency of your information in the SAM until you submit the final financial report required under this 

award or receive the final payment, whichever is later. This requires that you review and update the 

information at least annually after the initial registration, and more frequently if required by changes in your 

information or another award term.

B. Requirement for Data Universal Numbering System (DUNS) Numbers

If you are authorized to make subawards under this award, you:

1. Must notify potential subrecipients that no entity (see definition in paragraph C. of this award term) may 

receive a subaward from you unless the entity has provided its DUNS number to you.

2. May not make a subaward to an entity unless the entity has provided its DUNS number to you.

C. Definitions

For purposes of this award term:

1. System for Award Management (SAM) means the federal repository into which an entity must provide 

information required for the conduct of business as a recipient. Additional information about 

registration procedures may be found at the SAM Internet site at www.sam.gov. 

2. Data Universal Numbering System (DUNS) number means the nine- or thirteen-digit number established 

and assigned by Dun and Bradstreet, Inc. (D&B) to uniquely identify business entities. A DUNS number 

may be obtained from D&B by telephone (currently 866-705-5711) or the Internet at 

http://fedgov.dnb.com/webform. 

3. Entity, as it is used in this award term, means all of the following, as defined at 2 C.F.R. Part 25, subpart C:

a. A governmental organization which is a state, local government, or Indian Tribe;

b. A foreign public entity;

c. A domestic or foreign non-profit organization;

d. A domestic or foreign for-profit organization; and 

e. A federal agency, but only as a subrecipient under an award or subaward to a non-federal entity.

4. Subaward:

a. This term means a legal instrument to provide support for the performance of any portion of the 

substantive project or program for which you received this award and that you as the recipient 

award to an eligible subrecipient.

b. The term does not include your procurement of property and services needed to carry out the project 

or program (for further explanation, see Sec.__.210 of the attachment to OMB Circular A-133, 

“Audits of States, Local Governments, and Non-Profit Organizations”).

c. A subaward may be provided through any legal agreement, including an agreement that you 

consider a contract.
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5. Subrecipient means an entity that:

a. Receives a subaward from you under this award; and

b. Is accountable to you for the use of the federal funds provided by the subaward.

Why this condition:

The purpose of this standard award term is to ensure government-wide uniformity in establishing the DUNS 

number as the universal identifier for federal financial assistance applicants, as well as recipients and their direct 

subrecipients (if applicable), and to establish the SAM as the repository for standard information about 

applicants and recipients.

What you should do:

At the time of award application, your agency was required to provide its DUNS number and be registered in the 

SAM database. 

Your agency should continue to use the same DUNS number provided in your award application and update, as 

needed, the information associated with that DUNS number. If your agency is authorized to make subawards 

under its award, your agency may make subawards only to entities that have DUNS numbers. For more 

information about your DUNS number, please contact D&B using the toll-free number 866-705-5711 or visit 

fedgov.dnb.com/webform. 

Your agency must maintain active registration and current information in the SAM until you submit the final 

financial report or receive the final payment under your award, whichever is later. Your agency must review 

and update its SAM information at least once per year to maintain an active registration status. For more 

information about SAM registration, please visit www.sam.gov. 

16. Reporting Subawards and Executive Compensation

Condition:

The Office of Management and Budget requires federal agencies to include the following standard award term in all 

awards and cooperative agreements made on or after October 1, 2010: 

A. Reporting of first-tier subawards.

1. Applicability. Unless you are exempt as provided in paragraph D. of this award term, you must report 

each action that obligates $25,000 or more in federal funds that does not include Recovery funds (as 

defined in section 1512(a)(2) of the American Recovery and Reinvestment Act of 2009, Pub. L. 111–5) for 

a subaward to an entity (see definitions in paragraph E. of this award term).

2. Where and when to report.

a. You must report each obligating action described in paragraph A.1. of this award term to 

www.fsrs.gov. 

b. For subaward information, report no later than the end of the month following the month in which 

the obligation was made. (For example, if the obligation was made on November 7, 2010, the 

obligation must be reported by no later than December 31, 2010.)
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3. What to report. You must report the information about each obligating action that the submission 

instructions posted at www.fsrs.gov specify.

B. Reporting Total Compensation of Recipient Executives.

1. Applicability and what to report. You must report total compensation for each of your five most highly 

compensated executives for the preceding completed fiscal year, if— 

a. the total federal funding authorized to date under this award is $25,000 or more;

b. in the preceding fiscal year, you received— 

I. 80 percent or more of your annual gross revenues from federal procurement contracts (and 

subcontracts) and federal financial assistance subject to the Transparency Act, as defined at 2

C.F.R. Part 170.320 (and subawards); and

II. $25,000,000 or more in annual gross revenues from federal procurement contracts (and 

subcontracts) and federal financial assistance subject to the Transparency Act, as defined at 2 

C.F.R. Part 170.320 (and subawards); and

c. The public does not have access to information about the compensation of the executives through 

periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 

78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. To determine if the public has 

access to the compensation information, see the U.S. Security and Exchange Commission total 

compensation filings at www.sec.gov/answers/execomp.htm. 

2. Where and when to report. You must report executive total compensation described in paragraph B.1. of 

this award term:

a. As part of your registration profile at www.sam.gov. 

b. By the end of the month following the month in which this award is made, and annually thereafter.

C. Reporting of Total Compensation of Subrecipient Executives.

1. Applicability and what to report. Unless you are exempt as provided in paragraph D. of this award term, 

for each first-tier subrecipient under this award, you shall report the names and total compensation of 

each of the subrecipient’s five most highly compensated executives for the subrecipient’s preceding 

completed fiscal year, if— 

a. in the subrecipient’s preceding fiscal year, the subrecipient received— 

i. 80 percent or more of its annual gross revenues from federal procurement contracts (and 

subcontracts) and federal financial assistance subject to the Transparency Act, as defined at 2 

C.F.R. 170.320 (and subawards); and

ii. $25,000,000 or more in annual gross revenues from federal procurement contracts (and 

subcontracts), and federal financial assistance subject to the Transparency Act (and 

subawards); and

b. The public does not have access to information about the compensation of the executives through 

periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 

78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. To determine if the public has 
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access to the compensation information, see the U.S. Security and Exchange Commission total 

compensation filings at www.sec.gov/answers/execomp.htm. 

2. Where and when to report. You must report subrecipient executive total compensation described in 

paragraph C.1. of this award term:

a. To the recipient.

b. By the end of the month following the month during which you make the subaward.

For example, if a subaward is obligated on any date during the month of October of a given year 

(i.e., between October 1 and 31), you must report any required compensation information of the 

subrecipient by November 30 of that year.

D. Exemptions 

1. If, in the previous tax year, you had gross income, from all sources, under $300,000, you are exempt 

from the requirements to report:

a. Subawards, and

b. The total compensation of the five most highly compensated executives of any subrecipient.

E. Definitions. For purposes of this award term:

1. Entity means all of the following, as defined in 2 C.F.R. Part 25:

a. A governmental organization, which is a state, local government, or Indian Tribe;

b. A foreign public entity;

c. A domestic or foreign non-profit organization;

d. A domestic or foreign for-profit organization;

e. A federal agency, but only as a subrecipient under an award or subaward to a non-federal entity.

2. Executive means officers, managing partners, or any other employees in management positions.

3. Subaward:

a. This term means a legal instrument to provide support for the performance of any portion of the 

substantive project or program for which you received this award and that you as the recipient 

award to an eligible subrecipient.

b. The term does not include your procurement of property and services needed to carry out the project 

or program (for further explanation, see Sec. ___.210 of the attachment to OMB Circular A–133, 

“Audits of States, Local Governments, and Non-Profit Organizations”).

c. A subaward may be provided through any legal agreement, including an agreement that you or a 

subrecipient considers a contract.

4. Subrecipient means an entity that:

a. Receives a subaward from you (the recipient) under this award; and

b. Is accountable to you for the use of the federal funds provided by the subaward.
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5. Total compensation means the cash and noncash dollar value earned by the executive during the 

recipient’s or subrecipient’s preceding fiscal year and includes the following (for more information see 17 

C.F.R. 229.402(c)(2)):

a. Salary and bonus.

b. Awards of stock, stock options, and stock appreciation rights. Use the dollar amount recognized for 

financial statement reporting purposes with respect to the fiscal year in accordance with the 

Statement of Financial Accounting Standards No. 123 (Revised 2004) (FAS 123R), Shared Based 

Payments.

c. Earnings for services under non-equity incentive plans. This does not include group life, health, 

hospitalization, or medical reimbursement plans that do not discriminate in favor of executives, and 

are available generally to all salaried employees.

d. Change in pension value. This is the change in present value of defined benefit and actuarial 

pension plans.

e. Above-market earnings on deferred compensation which is not tax-qualified.

f. Other compensation, if the aggregate value of all such other compensation (e.g., severance, 

termination payments, value of life insurance paid on behalf of the employee, perquisites or 

property) for the executive exceeds $10,000.

Why this condition:

To further federal spending transparency, the Federal Funding Accountability and Transparency Act of 2006 

(FFATA) requires, among other things, that information on federal awards (federal financial assistance and 

expenditures) be made available to the public via a single, searchable website, which is 

www.USASpending.gov. Recipients are responsible for reporting their applicable executive compensation and 

subaward information and the award term provides guidance to report the related information, as required by 

FFATA.

What you should do:

At the time of award application, your agency was asked to ensure that it has the necessary processes and 

systems in place to comply with the applicable subaward and executive compensation reporting requirements 

should it receive funding. If your agency received awards of $25,000 or more, you are required to report award 

information on any first-tier subawards totaling $25,000 or more and, in certain cases, to report information on 

the names and total compensation of the five most highly compensated executives of the recipient and first-tier 

subrecipients. The FFATA Subaward Reporting System (FSRS), accessible via the Internet at www.fsrs.gov, is the 

reporting tool that your agency will use to capture and report subaward information and any executive 

compensation data required by FFATA. The subaward information entered in FSRS will then be displayed on 

www.USASpending.gov associated with your agency’s award to further federal spending transparency.

For additional information regarding the executive compensation and subaward reporting requirements, please 

see Vol. 75, No. 177 (September 14, 2010) of the Federal Register, www.gpo.gov/fdsys/pkg/FR-2010-09-

14/pdf/2010-22705.pdf. 
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17. Debarment and Suspension

Condition:

The recipient agrees not to award federal funds under this program to any party which is debarred or suspended from 

participation in Federal assistance programs.

Why this condition:

Under federal regulations, recipients are required to ensure that federal funds are not given to parties that are 

debarred or suspended from participation in federal assistance programs. This is to protect the public interest 

and to ensure proper management and integrity in federal activities by conducting business only with 

responsible parties. For details regarding the debarment and suspension requirements, please see 2 CFR Part 

180 (Government-wide Debarment and Suspension), and 2 CFR Part 2867 (DOJ-specific requirements.) 

What you should do:

If, under a COPS Office award, you enter into a contract for goods or services for $25,000 or more or any 

subaward, you must verify that the vendor or subrecipient and their respective principals (e.g., owners, top 

managers) with whom you intend to do business are not excluded or disqualified from participation in federal 

assistance programs. In addition, you must include a term or condition in the contract or subaward requiring the 

vendor or subrecipient to comply with subpart C of the OMB guidance in 2 CFR Part 180 (Government-wide 

Debarment and Suspension) and subpart C of 2 CFR Part 2867 (DOJ-specific requirements).

18. Employment Eligibility

Condition:

The recipient agrees to complete and keep on file, as appropriate, a Bureau of Citizenship and Immigration Services 

Employment Eligibility Verification Form (I-9). This form is to be used by recipients of federal funds to verify that 

persons are eligible to work in the United States.

Why this condition:

Under federal immigration law, all employers are required to take certain steps to ensure that persons that are 

hired are legally permitted to work in the United States. The Bureau of Citizenship and Immigration Services 

Employment Eligibility Verification Form (I-9) outlines the types of documents that an employer should review to 

confirm that a new hire is eligible for employment.

What you should do:

You do not need to submit any documentation to the COPS Office to satisfy this condition. Rather, you should 

complete and maintain the I-9 forms for all new employees under the guidelines set forth by the Bureau of 

Citizenship and Immigration Services. For further information about this requirement, you may contact the 

Bureau’s Office of Business Liaison at 800-357-2099 or the National Customer Service Center at 800-375-5283.
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19. Whistleblower Protection

Condition:

The recipient agrees not to discharge, demote, or otherwise discriminate against an employee as reprisal for the 

employee disclosing information that he or she reasonably believes is evidence of gross mismanagement of a federal 

contract or award, a gross waste of federal funds, an abuse of authority relating to a federal contract or award, a 

substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a Federal 

contract (including the competition for or negotiation of a contract) or award. The recipient also agrees to provide to 

their employees in writing (in the predominant native language of the workforce) of the rights and remedies provided 

in 41 U.S.C. § 4712. Please see appendix G in the Award Owner’s Manual for a full text of the statute.

Why this condition:

Under the “Pilot program for enhancement of contractor protection from reprisal for disclosure of certain 

information” (41 U.S.C. § 4712), which is in effect through January 1, 2017, recipients are prohibited from taking 

reprisal actions against employees for certain whistleblowing activities in connection with federal awards and 

contracts. The pilot program protects the public interest and ensures the proper management and use of federal 

funds. 

What you should do:

The recipient must not take reprisal actions against an employee for disclosing misconduct under federal 

contracts and awards to certain persons and entities.

The recipient is prohibited from discharging, demoting, or otherwise discriminating against an employee as 

reprisal for disclosing information that he or she reasonably believes is evidence of

• gross mismanagement of a federal contract or award;

• a gross waste of federal funds;

• an abuse of authority relating to a federal contract or award;

• a substantial and specific danger to public health or safety; or

• a violation of law, rule, or regulation related to a federal contract (including the competition for or 

negotiation of a contract) or award. 

In addition, the disclosure must also have been made to

• a member of Congress or a representative of a committee of Congress; 

• an inspector general;

• the Government Accountability Office; 

• a federal employee responsible for contract or award oversight or management at the relevant agency; 

• an authorized official of the U.S. Department of Justice or other law enforcement agency; 

• a court or grand jury; or

• a management official or other employee of the contractor, subcontractor, or recipient who has the 

responsibility to investigate, discover, or address misconduct. 

An employee is deemed to have made a protected disclosure if he or she initiates or provides evidence of 

misconduct in any judicial or administrative proceeding relating to waste, fraud, or abuse on a federal contract 

or award.
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The recipient must inform its employees in writing, in the predominant language of the workforce, of employee 

whistleblower rights, protections, and remedies under 41 U.S.C. § 4712. 

Please see appendix G on page 100 of this manual for a full text of the pilot program for enhancement of 

contractor protection from reprisal for disclosure of certain information (41 U.S.C. § 4712).

20. Mandatory Disclosure 

Condition:

Recipients and subrecipients must timely disclose in writing to the COPS Office or pass-through entity, as applicable, 

all federal criminal law violations involving fraud, bribery, or gratuity that may potentially affect the awarded federal 

funding. Failure to make required disclosures can result in any of the remedies, including suspension and debarment, 

described in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 

C.F.R. § 200.338 as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101.

Why this condition:

Federal regulations require recipients and subrecipients report all federal violations involving fraud, bribery, or 

gratuity that may affect the awarded federal funds. This condition advises your agency of the requirement and 

the consequences of failing to report such violations to the COPS Office or pass-through entity.

What you should do:

Ensure that you timely report in writing to the COPS Office or pass-through entity all federal violations involving 

fraud, bribery, or gratuity that may affect your federal award.

21. Conflict of Interest

Condition:

Recipients and subrecipients must disclose in writing to the COPS Office or pass-through entity, as applicable, any 

potential conflict of interest affecting the awarded federal funding in accordance with the Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 C.F.R. § 200.112 as adopted by the U.S. 

Department of Justice in 2 C.F.R. § 2800.101.

Why this condition?

Recipients and subrecipients are required to use federal funding in the best interest of their award program. Any 

decisions related to these funds must be free of hidden personal or organizational conflicts of interest, both in 

fact and in appearance.
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This means that recipients and subrecipients should not participate in any award-related decisions or 

recommendations that involve any of the following people or groups: 

• an immediate family member

• a partner

• an organization in which they are serving as an officer, director, partner, or employee

• any person or organization with whom they are negotiating or who has an arrangement concerning 

prospective employment, has a financial interest, or for other reasons can have less than an unbiased 

transaction with the recipient or subrecipient

This also means that recipients and subrecipients should avoid any action which might result in, or create the 

appearance of

• using your official position for private gain;

• giving special treatment to any person;

• losing complete independence or objectivity;

• making an official decision outside official channels; or

• affecting negatively the confidence of the public in the integrity of the Federal Government or the program.

What you should do:

Ensure that you report in writing to the COPS Office or pass-through entity, as applicable, any potential conflict 

of interest that may affect your federal award.

22. Contract Provision

Condition:

All contracts made by the award recipients under the federal award must contain the provisions required under 2 

C.F.R. Part 200, (Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards), 

as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101. Please see appendix H in the Award Owner’s 

Manual for a full text of the contract provisions.

Why this condition:

Federal regulations require recipients and subrecipients to comply with the necessary contract provisions in 

order to standardize and strengthen oversight of all contracts made under federal awards. This provision 

protects the public interest and ensures the proper management and use of federal funds as it relates to 

contracts entered into by the recipient. 

What you should do:

The recipient should review all contracts made under the federal award to ensure that they contain the 

provisions required in appendix H of the Award Owner’s Manual.
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23. Restrictions on Internal Confidentiality Agreements

Condition:

No recipient or subrecipient under this award, or entity that receives a contract or subcontract with any funds under 

this award, may require any employee or contractor to sign an internal confidentiality agreement or statement that 

prohibits or otherwise restricts the lawful reporting of waste, fraud, or abuse to an investigative or law enforcement 

representative of a federal department or agency authorized to receive such information.

Why this condition:

Under section 743 of Division E, Title VIII, of the Consolidated and Further Continuing Appropriations Act, 2016 

(Pub. L. 114-113), neither the recipient, subrecipient, nor any entity that receives a contract or subcontract with 

any funds under this or any other Act may require its employees or contractors to sign an internal confidentiality 

agreement or statement prohibiting or otherwise restricting their lawful reporting of waste, fraud, or abuse to an 

investigative or law enforcement representative of a federal department or agency. This provision protects the 

public interest and ensures the proper management and use of federal funds. This limitation is not intended, 

and shall not be understood by the agency making this award, to contravene requirements applicable to 

Standard Form 312 (which relates to classified information), Form 4414 (which relates to sensitive 

compartmented information), or any other form issued by a federal department or agency governing the 

nondisclosure of classified information.

What you should do:

In accepting this award, the recipient

• represents that it neither requires nor has required internal confidentiality agreements or statements 

from employees or contractors that currently prohibit or otherwise restrict (or purport to prohibit or 

restrict) employees or contractors from reporting waste, fraud, or abuse as described above;

• represents that, if it learns or is notified that it is or has been requiring its employees or contractors to 

execute agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict) 

reporting of waste, fraud, or abuse as described above, it will immediately stop any further obligations 

of award funds, will provide prompt written notification to the agency making this award, and will 

resume such obligations only if expressly authorized to do so by that agency.

If the recipient does or is authorized to make subawards or contracts under this award, in accepting, the 

recipient

• represents that it has or will determine that no other entity that the recipient proposes may or will 

receive award funds (whether through a subaward, contract, or subcontract) either requires or has 

required internal confidentiality agreements or statements from employees or contractors that 

currently prohibit or otherwise restrict (or purport to prohibit or restrict) employees or contractors from 

reporting waste, fraud, or abuse as described above;

• represents that it has or will make appropriate inquiry, or otherwise has an adequate factual basis, to 

support this representation;

• represents that, if it learns or is notified that any subrecipient, contractor, or subcontractor entity that 

receives funds under this award is or has been requiring its employees or contractors to execute 

agreements or statements that prohibit or otherwise restrict (or purport to prohibit or restrict) reporting 

of waste, fraud, or abuse as described above, it will immediately stop any further obligations of award 
2016 COPS Office Community Policing Development (CPD) Program Award Owner’s Manual

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funds to or by that entity, will provide prompt written notification to the agency making this award, and 

will resume (or permit resumption of) such obligations only if expressly authorized to do so by that 

agency.

24. Recipient Integrity and Performance Matters

Condition: 

The Office of Management and Budget requires federal awarding agencies to include the following standard award 

term in all awards over $500,000 made on or after January 1, 2016:

A. Reporting of Matters Related to Recipient Integrity and Performance

1. General Reporting Requirement

If the total value of your currently active awards, cooperative agreements, and procurement contracts 

from all Federal awarding agencies exceeds $10,000,000 for any period of time during the period of 

performance of this Federal award, then you as the recipient during that period of time must maintain 

the currency of information reported to the System for Award Management (SAM) that is made available 

in the designated integrity and performance system (currently the Federal Awardee Performance and 

Integrity Information System (FAPIIS)) about civil, criminal, or administrative proceedings described in 

paragraph 2 of this award term and condition. This is a statutory requirement under section 872 of 

Public Law 110-417, as amended (41 U.S.C. 2313). As required by section 3010 of Public Law 111-212, all 

information posted in the designated integrity and performance system on or after April 15, 2011, except 

past performance reviews required for Federal procurement contracts, will be publicly available.

2. Proceedings About Which You Must Report

Submit the information required about each proceeding that:

a. Is in connection with the award or performance of an award, cooperative agreement, or 

procurement contract from the Federal Government;

b. Reached its final disposition during the most recent five year period; and

c. Is one of the following:

(1) A criminal proceeding that resulted in a conviction, as defined in paragraph 5 of this award 

term and condition;

(2) A civil proceeding that resulted in a finding of fault and liability and payment of a monetary 

fine, penalty, reimbursement, restitution, or damages of $5,000 or more;

(3) An administrative proceeding, as defined in paragraph 5. Of this award term and condition, 

that resulted in a finding of fault and liability and your payment of either a monetary fine or 

penalty of $5,000 or more or reimbursement, restitution, or damages in excess of $100,000; or

(4) Any other criminal, civil, or administrative proceeding if:

i. It could have led to an outcome described in paragraph 2.c.(1), (2), or (3) of this 

award term and condition;

ii. It had a different disposition arrived at by consent or compromise with an 

acknowledgment of fault on your part; and

iii. The requirement in this award term and condition to disclose information about 

the proceeding does not conflict with applicable laws and regulations.
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3. Reporting Procedures

Enter in the SAM Entity Management area the information that SAM requires about each proceeding 

described in paragraph 2. of this award term and condition. You do not need to submit the information 

a second time under assistance awards that you received if you already provided the information 

through SAM because you were required to do so under Federal procurement contracts that you were 

awarded.

4. Reporting Frequency

During any period of time when you are subject to the requirement in paragraph 1. of this award term 

and condition, you must report proceedings information through SAM for the most recent five year 

period, either to report new information about any proceeding(s) that you have not reported previously 

or affirm that there is no new information to report. Recipients that have Federal contract, award, and 

cooperative agreement awards with a cumulative total value greater than $10,000,000 must disclose 

semiannually any information about the criminal, civil, and administrative proceedings.

5. Definitions

For purposes of this award term and condition:

a. Administrative proceeding means a non-judicial process that is adjudicatory in nature in order to 

make a determination of fault or liability (e.g., Securities and Exchange Commission Administrative 

proceedings, Civilian Board of Contract Appeals proceedings, and Armed Services Board of Contract 

Appeals proceedings). This includes proceedings at the Federal and State level but only in 

connection with performance of a Federal contract or award. It does not include audits, site visits, 

corrective plans, or inspection of deliverables.

b. Conviction, for purposes of this award term and condition, means a judgment or conviction of a 

criminal offense by any court of competent jurisdiction, whether entered upon a verdict or a plea, 

and includes a conviction entered upon a plea of nolo contendere.

c. Total value of currently active awards, cooperative agreements, and procurement contracts 

includes— 

(1) Only the Federal share of the funding under any Federal award with a recipient cost 

share or match; and

(2) The value of all expected funding increments under a Federal award and options, even 

if not yet exercised.

Why this condition:

Under 2 CFR § 200.210 (b) (1) (iii), recipients of awards in excess of $500,000 are required to report certain civil, 

criminal, and administrative proceedings if they have active federal awards, cooperative agreements, or 

contracts (or any combination of these) that total more than $10,000,000 during the COPS Office award period.

The purpose is to protect the public interest and to ensure proper management in federal activities by 

conducting business with responsible parties.

What you should do:

If the total value of your active awards, cooperative agreements, and contracts from all federal awarding 

agencies exceeds $10,000,000 during the COPS Office award period, then you must ensure that the proceedings 

described in paragraph 2 of this award term that are reported in the System for Award Management (SAM) are 

current. The information about the reported proceedings is made available in SAM via the designated integrity 

and performance system (currently the Federal Awardee Performance and Integrity Information System 
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29

(FAPIIS)). During the award period, you must either report for the most recent five-year period new information 

about any proceeding(s) that you have not reported previously or affirm that there is no new information to 

report. You must also disclose semiannually any information about criminal, civil, and administrative 

proceedings. 

25. Computer Network Requirement

Condition:

The recipient understands and agrees that no award funds may be used to maintain or establish a computer network 

unless such network blocks the viewing, downloading, and exchanging of pornography. Nothing in this requirement 

limits the use of funds necessary for any federal, state, tribal, or local law enforcement agency or any other entity 

carrying out criminal investigations, prosecution, or adjudication activities.

Why this condition:

Section 533 of Division B, Title V, of the Consolidated and Further Continuing Appropriations Act, 2016 (Pub. L.

114-113) prohibits the use of federal funds to maintain or establish a computer network that does not block the 

viewing, downloading, and exchanging of pornography. This provision protects the public interest in the proper 

management and use of federal funds.

What you should do:

The recipient must not use award funds to maintain or establish a computer network unless the network blocks 

pornography. This does not limit the use of funds for criminal investigations, prosecution, or adjudication 

activities.

26. Travel Costs

Condition:

Travel costs for transportation, lodging and subsistence, and related items are allowable under the CPD Program with 

prior approval from the COPS Office. Payment for allowable travel costs will be in accordance with 2 C.F.R. § 200.474 

(Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) as adopted by the 

U.S. Department of Justice in 2 C.F.R. § 2800.101.

Why this condition:

CPD funding will cover award-related travel costs for the recipient agency or other (non-recipient) individuals to 

attend training and technical assistance conferences, seminars, or classes or to visit a site specified in the original 

application. Allowable expenses for award-related lodging, meals, and incidental expenses that were included in 

the application were approved by the COPS Office as part of your agency’s CPD award and final budget. For 

more information, please refer to award condition #3 on page 5, “Allowable Costs.”

What you should do:

Your agency should refer to your FCM for a list of approved travel costs and use CPD funds only for approved 

travel costs incurred during the award period. In addition, your agency should keep timely and accurate records 

of all travel expenses. If at any time these costs change, you should immediately contact your COPS Office 

Program Manager. 
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27. Sole Source Justification

Condition:

CPD recipients who have been awarded funding for the procurement of an item (or group of items) or service in excess 

of $150,000 and who plan to seek approval for use of a noncompetitive procurement process must provide a written 

sole source justification to the COPS Office for approval prior to obligating, expending, or drawing down award funds 

for that item or service.

Why this condition:

In general, recipients are required to procure funded items through open and free competition. However, in 

some instances, recipients may have already determined that competition is not feasible.

What you should do:

If you have received an award for an item, group of items, or service in excess of $150,000 and have already 

determined that the award of a contract through a competitive process is infeasible, you must provide a written 

justification that explains why it is necessary to contract noncompetitively.

The initial determination that competition is not feasible can be made if one of the following circumstances 

exists:

• The item/service is available only from one source. 

• The public exigency or emergency for the requirement will not permit a delay resulting from competitive 

solicitation.

• The COPS Office authorizes noncompetitive proposals in response to a written request from the recipient.

• Competition is determined inadequate after solicitation of a number of sources.

The COPS Office will review your request and the supporting information that you provide and will make a 

determination as to whether or not an exception can be made to the general rule regarding competition. If 

submitting a sole source justification request to the COPS Office, please use the format described in appendix D, 

“Sole source justification facts,” on page 81 of this manual.

28. Public Release Information

Condition:

The recipient agrees to submit one copy of all reports and proposed publications resulting from this award ninety (90) 

days prior to public release. Any publications (written, curricula, visual, sound, or websites) or computer programs, 

whether or not published at government expense, shall contain the following statement: 

“This project was supported by Cooperative Agreement Number 2016-XX-XX-XXXX 

awarded by the Office of Community Oriented Policing Services, U.S. Department of 

Justice. The opinions contained herein are those of the author(s) and do not necessarily 

represent the official position or policies of the U.S. Department of Justice. References to 
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31

specific agencies, companies, products, or services should not be considered an 

endorsement by the author(s) or the U.S. Department of Justice. Rather, the references 

are illustrations to supplement discussion of the issues.

The Internet references cited in this publication were valid as of the date of this 

publication. Given that URLs and websites are in constant flux, neither the author(s) nor 

the COPS Office can vouch for their current validity.”

Why this condition:

The COPS Office wants to ensure the quality, objectivity, utility, and integrity of information in funded projects 

that are disseminated to the public. However, award-funded reports and publications are not works of 

authorship by the Federal Government and should not be construed to reflect the official policy or position of 

the U.S. Department of Justice.

What you should do:

Ensure that all publications relating to your COPS Office CPD award contain the required statement listed above.

29. Criminal Intelligence Systems

Condition:

Recipients using CPD funds to operate an interjurisdictional criminal intelligence system must comply with operating 

principles of 28 C.F.R. Part 23. The recipient acknowledges that it has completed, signed, and submitted the Reviews 

and Certifications form with its award application certifying compliance with 28 C.F.R. Part 23.

Why this condition:

If your agency receives funding for equipment or technology that will be used to operate an interjurisdictional 

criminal intelligence system, you must comply with the operating principles found in 28 CFR Part 23. An 

“interjurisdictional criminal intelligence system” is generally defined as a system that receives, stores, analyzes, 

exchanges, or disseminates data regarding ongoing pre-arrest criminal activities (examples of such activities 

include, but are not limited to, loan sharking, drug or stolen property trafficking, gambling, extortion, smuggling, 

bribery, and public corruption) and shares this data with other law enforcement jurisdictions. 28 CFR Part 23 

contains operating principles for these interjurisdictional criminal information systems that protect individual 

privacy and constitutional rights.

If your agency will use CPD award funds to operate a single agency database (or other unrelated forms of 

technology) and will not share criminal intelligence data with other jurisdictions, 28 CFR Part 23 does not apply 

to your award. 

What you should do:

All CPD recipients were required to agree to the Certification of Review of Criminal Intelligence Systems/28 CFR 

Part 23 as part of their application proposal so the COPS Office can track which agencies intend to use their 

award funds to operate interjurisdictional criminal intelligence systems. If your agency intends to use award 

funds to operate an interjurisdictional criminal intelligence system, you should have indicated this in your 
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application and certified your agency’s agreement to comply with the operating principles found at 28 CFR Part 

23. Your agency now must comply with 28 CFR Part 23 in operating the interjurisdictional criminal intelligence 

system funded through your CPD award.

30. State Information Technology Point of Contact

The recipient agrees to ensure that the appropriate State Information Technology Point of Contact receives written 

notification regarding any technology or information sharing project funded by this Community Policing 

Development award during the obligation and expenditure period. This is to facilitate communication among local 

and state governmental entities regarding various information technology projects being conducted with these 

award funds. In addition, the recipient agrees to maintain an administrative file documenting the meeting of this 

requirement. For a list of State Information Technology Points of Contact, go to

http://it.ojp.gov/default.aspx?area=policyAndPractice&page=1046. 

Why this condition:

The COPS Office is committed to promoting communication between state and local law enforcement.

What you should do:

If applicable, upon receiving the award, your agency should contact your state information technology point of 

contact for further guidance.

The COPS Office is committed to avoiding duplication of existing law enforcement information-sharing networks 

or IT systems that involve interagency connectivity between jurisdictions. Therefore, such COPS Office–funded 

systems should employ, to the extent possible, existing systems such as Law Enforcement Online (LEO), Regional 

Information Sharing Systems (RISS), Joint Regional Information Exchange System (JRIES), etc., to achieve 

interstate connectivity.

31. News Media

Condition:

The recipient agrees to comply with the COPS Office policy on contact with the news media. The policy establishes the 

COPS Office Communications Division as the principal point of contact for the news media for issues relevant to the 

COPS Office or parameters of this award. The recipient agrees to refer all media inquiries on these topics directly to the 

COPS Office Communications Division at 202-514-9079.

Why this condition:

The COPS Office Communications Division will coordinate contacts with the news media, provide supplemental 

information that may be helpful to you and the media outlet, and make the appropriate U.S. Department of 

Justice offices and personnel aware of pending articles and interviews. 

What you should do:

If you are contacted by a media outlet seeking information, an interview, or other support related to your COPS 

Office project, please refer the requesting outlet to the COPS Office Communications Division at 202-514-9079.
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32. Paperwork Reduction Act (PWRA)

Condition:

The recipient agrees, if required, to submit all surveys, interview protocols, and other information collections funded by 

this award to the COPS Office for submission to the Office of Management and Budget (OMB) for clearance under the 

Paperwork Reduction Act (PWRA) of 1995.

Why this condition:

The purpose of the Paperwork Reduction Act is to reduce, minimize, and control paperwork burdens on the 

public while maximizing the practical utility and public benefit of information created, collected, disclosed, 

maintained, used, shared, and disseminated by or for the Federal Government. See 5 CFR § 1320.1.

A collection of information undertaken by a recipient is considered to be conducted or sponsored by a federal 

agency only if (1) the recipient is conducting the collection of information at the specific request of the agency, 

or (2) the terms and conditions of the award require specific approval by the agency of the collection of 

information or the collection procedures. See 5 CFR § 1320.3(d).

What you should do:

When you undertake surveys, interviews, and other methods of information collection in furtherance of the 

objectives of the award, you should contact your COPS Office Program Manager. The COPS Office Program 

Manager will inform you whether Office of Management and Budget (OMB) approval of the information 

collection method is required and of the procedures necessary to obtain this approval. OMB approval may take 

several months to receive, so recipients are advised to allow ample time for the processing of this request.

33. Human Subjects Research 

Condition:

The recipient agrees to comply with the provisions of the U.S. Department of Justice’s common rule regarding 

Protection of Human Subjects, 28 C.F.R. Part 46, prior to the expenditure of Federal funds to perform such activities, if 

applicable. The recipient also agrees to comply with 28 C.F.R. Part 22 regarding the safeguarding of individually 

identifiable information collected from research participants.

Why this condition:

Protections for human subjects of research are required under U.S. Department of Justice regulations at 28 CFR 

Part 46. This regulation constitutes the Federal Policy (Common Rule) for the Protection of Human Subjects. Each 

institution engaged in (nonexempt) COPS Office–supported human subjects research must provide a written 

assurance of compliance, satisfactory to the COPS Office, that it will comply with the U.S. Department of Justice

human subjects regulations.

What you should do:

If any part of your CPD project contains research or statistical activities which involve human subjects that are 

not covered by an exemption set forth in 28 CFR Part 46.101(b), you should ensure that you meet the provisions 

of the U.S. Department of Justice’s common rule regarding human subjects research risk protections, 28 CFR Part 
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46, prior to the expenditure of federal funds to perform such activities. By signing the award document, you also 

agree to comply with 28 CFR Part 22 regarding the safeguarding of individually identifiable information 

collected from research participants.

34. Copyright 

Condition:

If applicable, the recipient may copyright any work that is subject to copyright and was developed, or for which 

ownership was acquired, under this award in accordance with 2 C.F.R. § 200.315(b). The COPS Office reserves a 

royalty-free, nonexclusive and irrevocable license to reproduce, publish, or otherwise use the work, in whole or in part 

(including create derivative works), for Federal Government purposes, and to authorize others to do so. The COPS 

Office also reserves the right, at its discretion, to not publish deliverables and other materials developed under this 

award as a U.S. Department of Justice resource.

When appropriate, U.S. Department of Justice publications and other deliverables developed under the Community 

Policing Development award should contain the following copyright notice: 

“Copyright © [year work was published] [name of copyright owner]. The U.S. Department 

of Justice reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, 

publish, or otherwise use, and authorize others to use, this resource for Federal 

Government purposes. This resource may be freely distributed and used for 

noncommercial and educational purposes only.”

Why this condition:

U.S. Department of Justice regulations allow the recipient of a CPD award to copyright any work that is subject 

to copyright and was developed, or for which ownership was purchased, under an award. 

As a Federal Government agency whose activities include producing and disseminating law enforcement 

materials to advance public safety through community policing across the nation, the COPS Office has an 

interest in making your deliverables and products widely available and accessible to the public. The COPS Office 

may make any work that was developed or purchased under this award publically available by any means 

without restriction, including a U.S. Department of Justice website, social media account, and hard or electronic 

copy. The COPS Office also reserves the right, at its discretion, to not publish deliverables and other materials 

(e.g., reports, publications, manuals, and training curricula) developed under this award as a U.S. Department of 

Justice resource.

What you should do:

The recipient is responsible for acquiring the rights, and ensuring that its subrecipients/contractors/authors 

acquire the rights, including the payment of required fees, to use copyrighted material for inclusion in 

deliverables that are developed under this award. All licensing, publishing, or similar agreements with a 

copyright holder, publisher, or other relevant party must include provisions giving the COPS Office a royalty-free, 

nonexclusive, and irrevocable license to reproduce, publish, or otherwise use the work in whole or in part 

(including create derivative works) for Federal Government purposes and to authorize others to do so. If the 

recipient retains a contractor or consultant to author or coauthor a work under this award, the recipient must 

ensure that there is a written agreement with the contractor or consultant that explicitly either (1) assigns and 
2016 COPS Office Community Policing Development (CPD) Program Award Owner’s Manual

35

transfers all rights to the copyright in the work to the recipient for the full term of copyright or (2) awards the 

COPS Office a royalty-free, nonexclusive, and irrevocable license to use, and authorize others to use, the work for 

Federal Government purposes.

The U.S. Department of Justice is a nonexclusive licensee to copyrighted work that was developed, or for which 

ownership was purchased, under this award. Only the legal or beneficial owner of an exclusive right under a 

copyright is entitled to institute an infringement action. The recipient should therefore consult its own legal 

counsel with any copyright infringement questions. For more information about registering a copyright, please 

visit the U.S. Copyright Office at www.copyright.gov. 

To help protect against unauthorized use, COPS Office–funded publications and other deliverables should 

contain the above-referenced copyright notice when appropriate.

What are the specific rules regarding termination of award funding?

The COPS Office has the right to sanction or terminate your agency’s project when there is reason to believe that 

your agency is

• not substantially complying with the award requirements or other applicable provisions of federal law; 

• failing to make satisfactory progress toward the goals or strategies outlined in its application; 

• not adhering to award requirements or conditions; 

• proposing substantial plan changes to the extent that, if originally submitted, would have resulted in the 

application being denied funding; 

• not submitting financial or programmatic reports in a timely manner; 

• filing false statements or certifications in connection with an application, periodic report, or other awardrelated documents; 

• providing other good cause for sanctions or termination as determined by the COPS Office. 

In these instances, the COPS Office may

• temporarily withhold payments pending correction of the situation by your agency; 

• disallow all or part of the cost of the activity or action not in compliance; 

• wholly or partly suspend or terminate your award; 

• require that some or all of the award funds be remitted to the U.S. Department of Justice; 

• condition a future award or elect not to provide future award funds to your agency until appropriate actions 

are taken to ensure compliance; 

• withhold or restrict your agency from obtaining future awards; 

• recommend civil or criminal enforcement by other agencies; 

• take other remedies that may be legally available. 

In the event that sanctions are imposed or your award is terminated, your agency will be notified in writing of 

our decision and the reason(s) for that decision.

Awards terminated due to non-compliance with the federal statutes, regulations, or award terms and conditions 

will be reported to the integrity and performance system accessible through SAM (currently FAPIIS).
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Accepting the award

After you have reviewed the conditions of your COPS Office CPD Program award and your agency agrees with 

these conditions, you are ready to accept the award. The Director (or Acting Director) of the COPS Office has 

signed the award document indicating approval of your award, an obligation of federal funds to your 

organization, and our commitment to the award. As stated at the beginning of this section, to officially begin 

your award and draw down your funds, the authorized officials (see the Glossary of Terms on page 107 of this 

manual) must access https://portal.cops.usdoj.gov and select the “Account Access” link in the upper-right 

corner to log in, review, and electronically sign the award document with the award terms and conditions; the 

Financial Clearance Memorandum and, if applicable, the cooperative agreement that is incorporated by 

reference into the award document; and, if applicable, the special award conditions and high risk conditions in 

the award document supplement within 90 days of the date shown on the award congratulatory letter. 

Who should sign the award document for our agency?

The authorized officials are the law enforcement and government executives who have ultimate and final 

responsibility for all programmatic and financial decisions regarding this award as representatives of the legal 

recipient. COPS Office awards require that both the top law enforcement executive (e.g., chief of police, sheriff, 

or equivalent) and the top government executive (e.g., mayor, board chairman, or equivalent) sign the award 

document. For non–law enforcement agencies (universities, private organizations, etc.), the authorized officials 

are the programmatic and financial officials who have the ultimate signatory authority to sign contracts on 

behalf of your organization. Typically, these are the same executives who signed the forms in your CPD 

application package. If one or both of these individuals have changed, please complete a Change of Information 

(COI) form online at https://portal.cops.usdoj.gov through the “Account Access” option. If you have any 

questions as to who should sign the award, please contact your organization’s legal counsel.

By when must the award document be signed?

Please electronically sign the award document and all award condition pages within 90 days of the date on the 

award congratulatory letter. Award funds will not be released until we have received your agency’s signed award 

document, your budget has received final clearance, and any other relevant award conditions particular to your 

agency have been satisfied. Failure to electronically sign your original award document within the 90-day award 

acceptance period may result in your CPD award being withdrawn and the funds deobligated without additional 

notification. If your agency requires an extension for accepting the award beyond the 90-day acceptance 

timeframe, you will be able to request an extension through the online system. Be sure to explain the 

circumstances that prevent your agency from electronically signing the award document within the 90-day 

period, and identify the date by which the award document will be signed. The COPS Office will review such 

requests on a case-by-case basis. The COPS Office reserves the right to deny requests to extend the 90-day 

award acceptance period. If you have any questions, please contact your COPS Office Grant Program Specialist at 

800-421-6770.
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II. The Cooperative Agreement

If your project requires substantial involvement on the part of the COPS Office, a multi-page cooperative 

agreement document will accompany your award document. Under the Federal Grant and Cooperative 

Agreement Act of 1977, a cooperative agreement is the legal instrument used by a federal agency to enter into a 

relationship with a state, local government, or other recipient when the principal purpose of assistance is to 

carry out a public purpose of support or stimulation authorized by federal law and substantial involvement is 

expected between the federal agency and the recipient. See 31 U.S.C. § 6305.

To officially accept and begin your CPD award, your agency must review the cooperative agreement document 

along with your award document and electronically sign for all documents within 90 days of the date shown on 

the award congratulatory letter. Please note that, if applicable to your award, the cooperative agreement is 

incorporated by reference into the award document and by signing the award document, your agency has 

entered into the cooperative agreement with the COPS Office and agrees to abide by all the requirements in the 

cooperative agreement.

Your agency will not be able to draw down funds until the COPS Office receives your electronically signed award 

document. 

Below is a sample 2016 cooperative agreement template that will be customized for your specific COPS Officefunded project. If you have any additional questions concerning your cooperative agreement, please contact 

your designated COPS Office Program Manager. 

I. Statement of authority

This cooperative agreement between the [Insert Agency Name] (“recipient”) and the U.S. Department of 

Justice, Office of Community Oriented Policing Services (“COPS Office”) is hereby entered into under the 

authority of 42 U.S.C. 3796dd et seq. The purposes of this cooperative agreement are described below.

II. Statement of background and purpose

A. Background:

[Insert background – should set the stage for the CA including why this effort is needed, history of effort to 

date and reasons why the effort is required now] 

[Insert project purpose – should clearly state rationale for the work] 

B. Primary objective:

[Insert project objective – should include what we hope to accomplish – could be a number of small 

objectives] 

III. Scope of Work

For a period hereinafter set forth, the COPS Office and the recipient will cooperatively furnish the necessary 

personnel, travel, supplies, and otherwise perform all things necessary for, or incident to, the performance of 

work (the accomplishment of functional objectives) as set forth below:
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A. Specifically, the COPS Office will do the following:

1. Designate a program manager to participate in the planning and management of this cooperative 

agreement and to coordinate project activities.

2. Provide information and technical assistance from government sources within available resources 

and as determined appropriate by the program manager.

3. Provide guidance to the recipient in the planning and development of strategies used in the 

project and in the coordination of the project with law enforcement agencies and organizations 

interested in contributing their support.

4. Work with the recipient to meet the designated project tasks and timelines.

5. Review and approve required reports specific to each cooperative agreement, which will include 

periodic progress and financial reports, deliverables, evaluations, and other documentation 

requiring COPS Office approval.

6. Review and approve all proposed changes in key staff assignments to the project and any 

significant changes in the partner’s role or responsibilities.

7. Review and approve all proposed writers of any project deliverables.

8. Permit the recipient to copyright any work that is subject to copyright and was developed, or for 

which ownership was acquired, under this cooperative agreement in accordance with 2 C.F.R. § 

200.315(b). The COPS Office reserves a royalty-free, nonexclusive and irrevocable license to 

reproduce, publish, or otherwise use the work, in whole or in part (including create derivative 

works), for Federal Government purposes, and to authorize others to do so. The COPS Office license 

applies to (1) the copyright in any work developed under this cooperative agreement including any 

related subaward or contract and (2) any rights of copyright to which the recipient, including its 

subrecipient or contractor, purchases ownership with support from this cooperative agreement. In 

addition, the COPS Office may make any work that was developed or purchased under this 

cooperative agreement publically available by any means without restriction, including a U.S. 

Department of Justice website or social media account, a hard copy, or in electronic form. The COPS 

Office also reserves the right, at its discretion, to not publish deliverables and other materials (e.g., 

reports, publications, manuals, and training curricula) developed under this cooperative agreement 

as a U.S. Department of Justice resource.

B. Specifically, the recipient will do the following:

1. Designate a project officer to work closely with the COPS Office and its designated program 

manager to achieve the tasks specified in this cooperative agreement. The project officer must be 

an employee (not a contractor or consultant) of the recipient organization and have the authority 

to propose and approve modifications pursuant to Section VIII. of this cooperative agreement.

2. Be responsible for acquiring the rights, and ensuring that its subrecipients/contractors/authors 

acquire the rights, including the payment of required fees, to use copyrighted material for inclusion 

in deliverables that are developed under this cooperative agreement. All licensing, publishing or 

similar agreements with a copyright holder, publisher or other relevant party must include 

provisions giving the COPS Office a royalty-free, non-exclusive, and irrevocable license to 

reproduce, publish, or otherwise use the work, in whole or in part (including create derivative 

works), for Federal Government purposes, and to authorize others to do so. If recipient retains a 

contractor or consultant to author or co-author a work under this cooperative agreement, the 

recipient must ensure that there is a written agreement with the contractor or consultant that 

either explicitly: (1) assigns and transfers all rights to the copyright in the work to the recipient for 
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the full term of copyright or (2) awards the COPS Office the same royalty-free, non-exclusive and 

irrevocable license to use, and authorize others to use, the work for Federal Government purposes 

as outlined in this cooperative agreement.

3. Represent and warrant that all deliverables under this cooperative agreement were produced in a 

manner that does not infringe or misappropriate the intellectual property rights, or violate the right 

to privacy, of any third party. The recipient will be responsible for defending or settling at its own 

expense any and all third party claims and liabilities arising out of or in connection with any 

infringement action related to work that was developed, or for which ownership was acquired, 

under this cooperative agreement.

4. Provide further detail on project plans as requested by the program manager.

5. Adhere to the requirements or tasks specified in this cooperative agreement and not deviate from 

them unless requested adjustments are first presented to and approved by the program manager.

6. Submit for prior approval or disapproval to the program manager any proposed changes in key 

staff assignments to this project and any significant changes in any partner’s role or responsibilities.

7. Submit for prior approval to the program manager proposed writers of any project deliverables. 

The program manager will need to review each writer’s resume and writing sample before 

approving the writer.

8. Obtain written approval from the COPS Office prior to obligating, expending, or drawing down 

cooperative agreement funds for the award of non-competitive contracts for goods or services 

(including equipment purchases) in excess of $150,000. See 2 C.F.R. § 200.324(b)(2).

9. Ensure that all proposed deliverables and publications follow and are in accordance with the COPS 

Office Editorial and Graphics Style Manual.

10. Submit one copy of all reports and proposed products and deliverables (written, visual, or sound; 

curricula, reports, or websites) or computer programs resulting from this cooperative agreement to 

the program manager 90 days prior to public release.

11. All products and deliverables (written, visual, or sound; curricula, reports, or websites) or computer 

programs developed under this cooperative agreement must contain the following statement: 

This project was supported by cooperative agreement number 2016-XX-XX-XXXX awarded by the 

Office of Community Oriented Policing Services, U.S. Department of Justice. The opinions contained 

herein are those of the author(s) and do not necessarily represent the official position or policies of 

the U.S. Department of Justice. References to specific agencies, companies, products, or services

should not be considered an endorsement by the author(s) or the U.S. Department of Justice. Rather, 

the references are illustrations to supplement discussion of the issues. The Internet references cited 

in this publication were valid as of the date of this publication. Given that URLs and websites are in 

constant flux, neither the author(s) nor the COPS Office can vouch for their current validity.

When appropriate, U.S. Department of Justice publications and other products and deliverables 

developed under this cooperative agreement should contain the following copyright notice:

Copyright © [year work was published] [name of copyright owner]. The U.S. Department of Justice 

reserves a royalty-free, nonexclusive, and irrevocable license to reproduce, publish, or otherwise use, 

and authorize others to use, this resource for Federal Government purposes. This resource may be 

freely distributed and used for noncommercial and educational purposes only.
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12. Contact the program manager to determine if revenue generated from your award constitutes 

program income. Program income must be used to defray program costs and reduce the federal 

share of the project. See 2 C.F.R. § 200.307. In some cases, the recipient can work with the program 

manager to identify additional project-related allowable costs that could be supported by program 

income.

13. Not earn or keep any profit resulting from this award unless expressly authorized, in writing, by the 

COPS Office. See 2 C.F.R. § 200.400(g).

14. Ensure that all electronic and information technology deliverables (websites and web-based 

information, video and multimedia products, compact disks, software applications and operating 

systems, and telecommunication products) are developed and produced in a format that is 

accessible according to Section 508 accessibility requirements. Specifically, video should contain 

closed-captioning and audio description options. Electronic publications should be created in 

HTML, fully tagged PDFs, or accessible text file format and all web sites must be fully compliant with 

508 accessibility standards. For more information on Section 508 accessibility requirements, consult

the Section 508 website at www.section508.gov/. 

15. Ensure that web-based courses developed through this cooperative agreement are compatible 

with the current framework used in the Community Policing Learning Portal. Prior to the 

development of the web-based course, the recipient must contact the COPS Office to receive 

guidance to ensure this compatibility. At the request of the COPS Office, recipients must submit 

web-based courses that are developed through this cooperative agreement to the COPS Office.

16. At the request of the COPS Office, submit all website(s) and web-based information that are 

developed through this cooperative agreement to the COPS Office. The information must be 

submitted in a format that will enable the COPS Office to reproduce the website(s) and web-based 

information on alternative web-based platforms.

17. If required, submit all surveys, interview protocols, and other information collections to the COPS 

Office for submission to the Office of Management and Budget (OMB) for clearance under the 

Paperwork Reduction Act (PWRA) of 1995.

18. Agree to cooperate with the monitor or evaluator if monitoring or an evaluation of this project is to 

be undertaken by the COPS Office or a third party and, in consultation with the COPS Office, agree 

to make reasonable adjustments to programs and activities in recognition of significant points of 

evaluation or feedback and to remedy any violations of the terms and conditions of this award.

19. Be responsible for the development, approval, and oversight of any subawards. See 2 C.F.R. §§ 

200.330 - 200.332. The recipient will ensure that the award terms and conditions flow down to its 

subrecipients including all applicable uniform administrative requirements, costs principles, and 

audit requirements set forth in 2 C.F.R. Part 200. See 2 C.F.R. § 200.101(b)(1). The recipient will also 

ensure that subrecipients maintain effective control and accountability over all funds, property and 

other assets covered by subawards and that each subrecipient establishes and uses internal fiscal 

and program management procedures sufficient to prevent fraud, waste, or abuse.

20. At the request of the COPS Office, work to develop a marketing plan to increase the visibility of the 

project and any accompanying outcomes/deliverables. The recipient will coordinate any marketing 

activities with the COPS Office.

21. Coordinate all public communication activities (in any format including website and social media 

content) related to this project or the COPS Office with the program manager prior to release.

22. Work closely with the COPS Office and program manager to respond to peer reviewer, program 

manager, vetting, and other COPS Office staff comments prior to the cooperative agreement 

expiration date.
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23. Obtain written approval from the COPS Office prior to entering into any contract, agreement, or 

other obligation for costs related to any conference, meeting, retreat, seminar, symposium, training 

activity, or similar event funded that requires conference cost approval per DOJ conference cost 

policy under this award. For more information on allowable costs for conferences and training, 

please see the 2016 DOJ Financial Guide available at 

www.ojp.gov/financialguide/DOJ/index.htm. 

24. Ensure that all conference or similar event costs comply with current and future guidelines and 

policies that you receive from the COPS Office on conference planning, food and beverages, 

minimizing costs, and conference cost reporting.

25. Within 45 days after the end of any conference, meeting, retreat, seminar, symposium, training 

activity, or similar event funded under this award, and the total cost of which exceeds $20,000 in 

award funds, the recipient must provide the program manager with the following information and 

itemized costs:

• Name of the event

• Event dates

• Location of event

• Number of federal attendees

• Number of nonfederal attendees

• Costs of event space, including rooms for break-out sessions

• Costs for audio visual services

• Other equipment costs (e.g., computer fees, telephone fees)

• Costs of printing and distribution 

• Costs of meals provided during the event

• Costs of refreshments provided during the event

• Costs of event planner

• Costs of event facilitators

• Any other direct costs associated with the event

The recipient must also itemize and report any of the following attendee (including participants, 

presenters, speakers) costs that are paid or reimbursed with cooperative agreement funds:

• Meals and incidental expenses (M&IE portion of per diem)

• Lodging

• Transportation to/from event location (e.g., common carrier, privately owned vehicle (POV))

• Local transportation (e.g., rental car, POV) at event location

• Note that if any item is paid for with registration fees, or any other non-award funding, then 

that portion of the expense does not need to be reported. 

26. If applicable, submit by the 5th day of each month, information on all training and technical 

assistance events funded under this award to the COPS Office. Reporting instructions are outlined 

in the COPS Office Training and Technical Assistance Reporting Guide.
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27. If applicable, submit all approved indirect cost rates covering the award period to the COPS Office 

within 30 days of approval from the cognizant federal agency. 

If a provisional indirect cost rate is in effect at award closeout, the recipient will proceed with 

closeout and complete an expenditure analysis upon receipt of the approved final indirect cost rate 

to determine if an adjustment is necessary. If the recipient drew down excess COPS Office funding 

for indirect costs, the recipient must return the overpayment to the COPS Office. If the recipient 

incurred additional indirect costs, the recipient may request a budget modification if the award is 

still open and there are remaining award funds available for drawdown. If the recipient returns or 

draws down COPS Office funding, the recipient will promptly submit a revised final Federal 

Financial Report (SF-425).

The recipient should pay particular attention to the two areas listed below to ensure that their 

application of indirect cost rate is in compliance with the existing requirements of the governmentwide award rules set out by the Office of Management and Budget (OMB):

a. $25,000 Subcontract/Subaward Limitation: Indirect cost rates negotiated on the basis of 

modified total direct costs may only be applied against the first $25,000 of any subcontract or 

subaward under the agreement. This limitation must be applied to all conference related 

subcontracts and subawards, including those with hotels and travel agents. See 2 C.F.R. § 200, 

Appendix III.C.2 (Indirect costs—Institutions of Higher Education); 2 C.F.R. § 200, Appendix 

IV.B.2c (Indirect costs—Nonprofit Organizations); or 2 C.F.R. § 200, Appendix VII.C.2c (Indirect 

costs—States, Local Governments, and Indian Tribes). 

b. Participant Support Costs: Participant support costs are generally excluded from the 

distribution base. Therefore, indirect costs may not be applied against participant support 

costs. Participant support costs are direct costs for items such as stipends or subsistence 

allowances, travel allowances, and registration fees paid to or on behalf of participants or 

trainees (but not employees) in connection with meetings, conferences, symposia, or training 

projects. See 2 C.F.R. § 200.75. This exclusion applies to the entirety of any subcontracts for the 

lodging and travel of conference participants or trainees (but not employees). Costs related to 

contractors of the recipient who are acting in the capacity of a “Conference Trainer/Instructor/ 

Presenter/Facilitator” are considered participant support costs.

For more information on allowable costs for conferences and training, please see the 2016 DOJ 

Financial Guide available at www.ojp.gov/financialguide/DOJ/index.htm. 

Indirect costs were removed from the budget if the recipient did not provide, at the time of 

application, either a current approved federal indirect cost rate or documentation showing a 

pending request for approval by the cognizant federal agency. If the recipient has never received a 

federally approved indirect cost rate, it may elect to charge a de minimis rate of 10% of modified 

total direct costs (MTDC) in lieu of negotiating a rate with the cognizant federal agency. See 2 CFR § 

200.414(f).

28. Follow the COPS Office Curriculum Standards, Review and Approval Guide and COPS Office 

Instructor Quality Assurance Guide, if developing training curriculum or delivering training under 

this cooperative agreement. A copy of these guides will be supplied to you by the program 

manager.
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29. Notify and consult with the COPS Office prior to establishing a formal partnership with any nonfederal entity, including soliciting and accepting free goods or services, on activities under this 

cooperative agreement.

C. The recipient acknowledges the following:

1. If any part of the funded project contains research or statistical activities which involve human 

subjects that are not covered by an exemption set forth in 28 C.F.R. § 46.101(b), the recipient must 

meet the provisions of the U.S. Department of Justice’s common rule regarding the Protection of 

Human Subjects, 28 C.F.R. Part 46, prior to the expenditure of federal funds to perform such 

activities. The recipient also agrees to comply with 28 C.F.R. Part 22 regarding the safeguarding of 

individually identifiable information collected from research participants.

2. Implementation of this award will be subject to federal monitoring, auditing, or evaluation, and/or 

a single audit in accordance with 2 C.F.R. § 200.501. The recipient agrees to cooperate with such 

activities by providing access to and copies of, as appropriate, all project-related records, 

documents and personnel. A recipient that expends $750,000 or more in federal funds (from all 

sources) during the recipient’s fiscal year must have a single audit conducted in accordance with 2 

C.F.R. § 200.514, except when it elects to have a program-specific audit conducted in accordance 

with 2 C.F.R. § 200.501(c). For-profit (commercial) entities should follow the dollar threshold in 2 

C.F.R. § 200.501 in determining whether to conduct an audit in accordance with the Government 

Auditing Standards.

3. Failure to comply with the terms and conditions of this award may result in legal sanctions 

including, but not limited to, suspension and termination of funds, repayment of expended funds, 

and ineligibility to receive additional COPS Office funding.

4. False statements or claims made in connection with COPS Office awards may result in fines, 

imprisonment, debarment from participating in federal awards or contracts, or any other remedy

available by law to the Federal Government.

D. Specific requirements

At a minimum, the following specific requirements will be fulfilled by the recipient during the specified 

timeframe.

[Tasks should include performance indicators. How will the performance be measured? What tasks must 

be accomplished to get the desired results/outcomes?]

Task 1. 

Task 2. 

Task 3. The recipient will produce a standalone executive summary document(s) for [specify 

document/deliverables]. This document(s) is intended for use by law enforcement executives and 

others interested in an abridged version of the resource(s) developed under this award, and it will 

summarize the recipients’ work and highlight the major findings and recommendations. This 

document(s) will be subject to COPS Office review and approval. [This task should be included in all CAs 

when it is applicable. For example, it may not be applicable to training awards or when the documents 

produced are already abridged/summarized]. 

Task 4. Work with the COPS Office and the program manager to address peer review, program manager, 

vetting, and other COPS Office staff comments regarding [specify products and deliverables].
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E. Performance timeline and deliverables 

The following is a performance timeline for all deliverables and their due dates (based upon an award 

date of XX/XX/XXXX) which are considered to be significant in the performance of this cooperative 

agreement. One electronic copy of deliverable items will be delivered and in accordance with the 

following schedule:

Deliverables Date

[List Project Deliverables]

All deliverable items will be furnished to the following:

[Insert Program Manager]

U.S. Department of Justice

COPS Office

[Division]

145 N Street NE, 11th Floor

Washington, DC 20530

[insert contact information]

F. Financial status reports

The recipient will provide quarterly reports of project activity and expenditures. Specifically, the 

recipient is required to submit quarterly Federal Financial Reports on the Standard Form 425 (SF-425) 

within 30 days after the end of each quarter (January 1–March 31 / April 1–June 30 / July 1–September 

30 / October 1–December 31). A final SF-425 is due within 90 days after the end of the award period. 

Recipients must submit the quarterly SF-425 online. Visit the COPS Office website at 

https://portal.cops.usdoj.gov and select the “Account Access” link in the upper right corner to log in, 

complete, and submit reports online.

G. Programmatic progress reports

The recipient will provide periodic progress reports detailing project activity. Specifically, the recipient 

will submit progress reports through the COPS Office online progress reporting system in the frequency 

requested. These progress reports should be received by the COPS Office within 30 days of the end of 

the reporting period. The recipient will also submit a final progress report to the COPS Office within 90 

days of the end of the award period.

IV. Period of performance 

The period of performance of this cooperative agreement is XXX months from the cooperative agreement 

award start date (award period XX/XX/20XX to XX/XX/20XX).

V. Financial administration

A. Funding

The total amount of federal funding to be provided under this cooperative agreement is stated on the 

award document, award congratulatory letter, and official Financial Clearance Memorandum (FCM).
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B. Travel

All travel plans related to the cooperative agreement and to the development of the deliverables will be 

submitted to the program manager for review by the COPS Office.

Travel costs for transportation, lodging and subsistence, and related items are allowable under the CPD with 

prior approval from the COPS Office. Payment for allowable travel costs will be in accordance with 2 C.F.R. § 

200.474.

C. Consultant rates

Unless otherwise approved by the COPS Office, approved consultant rates will be based on the salary a 

consultant receives from his or her primary employer, as applicable, up to $650 per day. For consultant or 

contractor rates which exceed $650 per day, the COPS Office requires written justification if the consultants 

or contractors are hired through a noncompetitive bidding process. Authorization requires submitting a 

detailed written justification of the consultant rate to the program manager. Specific and detailed written

justification for each additional consultant must be submitted to and approved by the COPS Office prior to 

obligation or expenditure of such funds.

D. Project budget

The approved project budget is incorporated herein and made a part of this cooperative agreement. For 

federal awards in excess of $150,000, any modification request involving the reallocation of funding 

between budget categories that exceed or are expected to exceed 10 percent (10%) of the total approved 

budget requires prior written approval by the COPS Office. See 2 C.F.R. § 200.308(e). Regardless of the 

federal award amount or budget modification percentage, any reallocation of funding is limited to 

approved budget categories. In addition, any budget modification that changes the scope of the project 

requires prior written approval by the COPS Office. See 2 C.F.R. § 200.308(c).

In requesting a modification, the recipient will set forth the reasons and the basis for the proposed change 

and any other information deemed helpful for review by the COPS Office. Modifications are evaluated on a 

case-by-case basis. The COPS Office will not approve any modification request that results in an increase of 

federal funds.

E. Payment

All costs claimed for reimbursement and payment, including the final payment, must be submitted via the 

Grant Payment Request System (GPRS).

F. No-cost extensions of time

The recipient must provide a reasonable justification for delays in implementing this cooperative agreement 

to be granted a no-cost extension. A request for an extension of the award period to receive additional time 

to implement the funded program is at the discretion of the COPS Office. Such extensions do not provide 

additional funding.

G. Employment

The recipient acknowledges that nothing in this cooperative agreement creates an employment 

relationship with the COPS Office or with the Federal Government or to require provision of any benefits 

incident to employment.
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VI. Points of contact

A. COPS Office program manager

[Insert Program Manager]

U.S. Department of Justice

COPS Office

[Division]

145 N Street, NE, 11th Floor

Washington, DC 20530

[insert contact information]

B. Recipient project officer

[Insert contact information, including phone number]

VII. General provisions

The recipient of record must follow all requirements imposed by the U.S. Department of Justice as an award 

term, condition or administrative requirement of the award, including but not limited to: the COPS Office 

Community Policing Development Program Award Owner’s Manual; the COPS Office Assurances and 

Certifications; the COPS Office statute (42 U.S.C. 3796dd et seq.); 2 C.F.R. Part 200 (Uniform Administrative 

Requirements, Cost Principles, and Audit Requirements for Federal Awards); the current edition of the COPS 

Office Grant Monitoring Standards and Guidelines; the COPS Office Editorial and Graphics Style Manual; and 

all other applicable program requirements, laws, orders, regulations, or circulars.

Pursuant to Executive Order 13513, “Federal Leadership on Reducing Text Messaging While Driving,” the 

COPS Office encourages recipients of U.S. Department of Justice funds to adopt and enforce policies that 

ban text messaging while driving and to establish workplace safety policies to decrease crashed caused by 

distracted drivers.

VIII. Modifications

The designated COPS Office program manager and recipient project officer (under section VI (A) and VI (B)) 

for their respective organizations have the authority to propose and approve any modifications to this 

cooperative agreement. Modifications to this cooperative agreement may be proposed at any time during 

the period of performance by either party, and will become effective upon written approval by both parties.
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IX. Incorporation by reference; effective date

By signing the award document, the responsible parties designated below have entered into this 

cooperative agreement, which is incorporated by reference into the award document. This cooperative 

agreement is effective as of the date that the last responsible party signs the award document.

Ronald L. Davis, Director

Office of Community Oriented Policing Services

[Insert Law Enforcement Executive/Program Official Name]

[Insert Agency Name]

[Insert Government Executive/Financial Official Name]

[Insert Agency Name]

Updated September 2016
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III. Procurement Process

In general, recipients are required to procure funded items through open and free competition when feasible. 

For the purchase of equipment, technology, or services under a COPS Office award, recipients must follow their 

own policies and procedures on procurement as long as those requirements conform to the federal 

procurement requirements set forth in 2 CFR §§ 200.317 – 200.326.

As described in award condition #27 on page 30, recipients are required to submit a sole source justification 

(SSJ) request to the COPS Office for noncompetitive procurements in excess of $150,000 prior to purchasing 

equipment, technology, or services; obligating funding for a contract; or entering into a contract with award 

funds. If submitting a sole source justification request to the COPS Office, please use the format described in 

appendix D, “Sole source justification facts,” on page 81 of this manual.

If you have any questions regarding the federal requirements that guide procurement procedures, please 

contact your COPS Office Program Manager. 

For more information about COPS Office programs and resources, please call the COPS Office Response Center 

at 800-421-6770 or visit the COPS Office online at www.cops.usdoj.gov. 
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IV. Accessing Award Funds

This section provides answers to payment-related questions, including all the information needed to set up your 

payments. For assistance with financial management and award administration, please contact the COPS Office 

Response Center at 800-421-6770 or visit our website at www.cops.usdoj.gov/. 

Payment method

What method of payment is used?

There is currently one payment system available for accessing federal award funds—the Grant Payment Request 

System (GPRS). GPRS is a web-based system that enables recipients to use a secure Internet connection to 

request funds. Approved payment requests will automatically be scheduled for payment by the United States 

Department of the Treasury through electronic funds transfer (EFT). The Automated Clearing House (ACH) is the 

primary system that agencies use for EFT. An award recipient will be able to review previous payment requests 

made since July 2009. For more information regarding GPRS, please go to 

www.ojp.usdoj.gov/about/offices/ocfogprs.htm to view the User Guide.

Setting up your account

How do we set up a new GPRS account?

If you are a new recipient to the COPS Office, your agency should determine which authorized employee(s) will 

be responsible for requesting federal funds for your COPS Office awards through the GPRS system. The 

individual(s) selected must click on https://grants.ojp.usdoj.gov/gprs/welcome and register with the GPRS 

system to become a Drawdown Specialist for your agency. 

Once you have been approved, you will receive an e-mail containing a temporary password and information on 

how to use GPRS. Please note that part of the verification process may involve outreach to your law enforcement 

executive and/or government executive or other financial points of contact to validate the information that was 

provided during the registration process. All individuals that need access to GPRS must register separately and 

create their own unique GPRS username account, as these accounts are not meant to be shared.

How do we add an award to an existing GPRS account?

If you are currently registered for a COPS Office award username in GPRS and would like to add a recently 

awarded COPS Office award to the existing COPS Office award username, contact the COPS Office GPRS 

registration team via e-mail at COPSGPRSRegistration@usdoj.gov and provide the following information:

• User name (for COPS Office awards)

• First/last name

• Vendor number (as listed on your award document)

• Award number(s) to be added
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How do we fill out the payment enrollment forms?

If you are a new recipient to the COPS Office, your agency will need to complete an Automated Clearinghouse 

(ACH) Vendor/Miscellaneous Payment (SF-3881) enrollment form. This form can be found on the COPS Office 

website at the following address: www.cops.usdoj.gov/pdf/ach_form_new.pdf. 

Prior to accessing your award funds, your agency must mail the original signed form to:

Office of Justice Programs

Office of the Chief Financial Officer 

810 Seventh Street NW

Attn: Control Desk, Fifth Floor

Washington, DC 20001

Your agency must complete the “Payee/Company Information” section following the directions on the back of 

the form and also provide the award number (printed on the award document). Next, your financial institution 

must complete the “Financial Institution Information” section and have the appropriate financial official sign the 

form.

If you are already a COPS Office award recipient, you should already have filled out an ACH enrollment form. 

Therefore, your agency will not be required to submit a new ACH enrollment form for the new award as long as 

your OJP vendor number has not changed. If you have any questions, or wish to verify your ACH enrollment 

form information, please call the COPS Office Response Center at 800-421-6770 and ask to speak with your state 

assigned Staff Accountant.

When should Federal Financial Reports be filed?

After your agency returns the signed award document to the COPS Office, under current regulations, you are 

required to submit quarterly Federal Financial Reports (FFRs) using a Standard Form 425 (SF-425). This report 

reflects the actual monies spent and unliquidated obligations incurred by your agency. You will not be able to 

make drawdowns from your GPRS account if the SF-425 for the most recent reporting quarter is not on file with the 

COPS Office by the deadline date. Awardees are encouraged to submit their SF-425 reports via the Internet at 

https://portal.cops.usdoj.gov/. 

For more information on how to complete and where to submit your quarterly SF-425, see section VII of this 

manual, titled “Reports,” on page 58. 

Filing the Federal Financial Report (SF-425) identifies your federal and local expenditures made during that calendar 

quarter. However, to receive actual payment, you must request it through GPRS.
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Additional payment questions

Can we receive advances?

Yes. If you receive funds through electronic transfer, the period allowed is 10 days in advance. In general, the 

concept of “minimum cash on hand” applies to COPS Office awards. This concept requires that your agency 

request funds based upon immediate cash disbursement needs. You should time your request for payment to 

ensure that federal cash on hand is the minimum that you need.

There should be no excess federal award funds on hand, except for advances not exceeding 10 days, as noted 

above.

The Federal Government has four basic rules regarding advances. Advances can be terminated if the recipient

1. is unwilling or unable to attain project goals;

2. maintains excess cash on hand;

3. does not adhere to the terms and conditions of the award; and/or

4. fails to submit reliable or timely reports.

How often can we request reimbursement of costs?

There are no limitations on how often your agency may request reimbursements; however, your reimbursement 

requests should cover a specific time frame and include only costs that were approved in the Financial Clearance 

Memorandum (FCM). As a general guideline, most agencies request reimbursement on a monthly or quarterly 

basis. Also, please note that a date range for a reimbursement request can only be used once.

Can we earn interest on our award funds?

For states, payments are governed by Treasury-State CMIA agreements and default procedures codified at 31 

CFR Part 205 ‘‘Rules and Procedures for Efficient Federal-State Funds Transfers’’ and TFM 4A–2000 Overall 

Disbursing Rules for All Federal Agencies.

For nonfederal entities other than states, payment methods must minimize the time between your drawdown of 

federal funds and your payment of award costs to avoid earning excess interest on your award funds. You must 

account for interest earned on advances of federal funds as follows:

• The Office of Management and Budget (OMB) uniform guidance at 2 C.F.R. § 200.305(b)(9) states that

interest earned on federal advance payments deposited in interest-bearing accounts up to $500 per year

may be retained by the nonfederal entity for administrative expenses. 

• Any interest earned on federal advance payments deposited in interest-bearing accounts that is in excess 

of $500 per year must be remitted annually to the Department of Health and Human Services Payment 

Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) 

network or a Fedwire Funds Service payment. For detailed information on remittance please see appendix I 

on page 106 for a full text of the electronic medium remittance options.
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• If you do not have access to an electronic medium option, then please make a check payable to “The 

Department of Health and Human Services” and mail the check to Treasury-approved lockbox: HHS Program 

Support Center, P.O. Box 530231, Atlanta, GA 30353-0231. (Please allow 4–6 weeks for processing of a 

payment by check to be applied to the appropriate Payment Management System (PMS) account).

• Please notify your COPS Office Staff Accountant in the COPS Office Finance Business Unit when any interest 

that is earned is remitted to the Department of Health and Human Services, Payment Management System.

Matching funds

Under the COPS Office Community Policing Development Program, no local match is required. The COPS Office

is funding 100 percent of the allowable items approved in your FCM. Any agency desiring to contribute 

additional funds to this project is encouraged to do so and report these funds on SF-425 as a recipient share of 

expenditures.
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V. Financial Record Maintenance

Under the COPS Office CPD Program, your agency is required to establish and maintain accounting systems and 

financial records to accurately account for funds awarded and disbursed. These records must include both 

federal funds and any local funds contributed to this project.

Accounting systems and records 

What accounting systems are required?

Your agency needs to establish and maintain accounting systems and financial records to accurately account for 

the funds awarded.

As required by 2 CFR. § 200.62 (Internal control over compliance requirements for federal awards), your

accounting system should be designed to provide reasonable assurance regarding the achievement of the 

following objectives for federal awards:

• Transactions are properly recorded and accounted for in order to prepare reliable financial statements and 

federal reports and to maintain accountability over assets. 

• Transactions are executed in compliance with all applicable federal statutes, regulations, and the award 

terms and conditions.

• Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition.

What records must be kept?

Your agency’s fiscal control and accounting systems should enable you to make accurate, current, and complete 

disclosure of the financial activity under your CPD award. Your accounting records should contain information 

showing expenditures under the award and must be supported by items such as payroll records, time and 

attendance records, canceled checks, purchase orders, or similar documents.

Your agency must adequately safeguard award funds and make sure that they are used for authorized purposes 

only. Your agency will be responsible for refunding any unallowable expenses.

How long must records be kept? 

All financial records and supporting documents associated with your CPD award (including payroll, time and 

attendance records, canceled checks, and purchase order) must be retained for a period of three years from the 

date of submission of the final expenditure report as stated in 2 CFR §200.333 (Retention requirements for 

records).

Your agency should maintain records so that you can identify them by award year or by fiscal year, whichever

you find more convenient. If any litigation, claim, negotiation, audit, or other action involving these records has 

been started before the end of the three-year period, the records should be kept until completion of the action.

These records should be easily located and should be properly protected against fire or other damage. Failure to 

maintain adequate records to document award expenditures may result in a requirement to repay all federal funds 

that cannot be supported with appropriate records.
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What if we have more than one award?

If your agency has more than one COPS Office award or an award from another federal agency, funds received 

under one project may not be used to support another project without specific written authorization from the 

COPS Office, or in the case of an award from another agency, from both awarding agencies. Your accounting 

systems and financial records must reflect expenditures for each project separately.

Who may access our records?

Authorized federal representatives, including representatives from the U.S. Department of Justice, the 

Comptroller General of the United States, the COPS Office, and any entity designated by the COPS Office may 

access these records for the purposes of conducting audits, site visits, or other examinations.
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VI. Federal Audit Requirements

In addition to oversight by the COPS Office, your award may be subject to an audit by independent examiners. 

The two primary types of audit are Single Audit Act (SAA) audits and U.S. Department of Justice, Office of the 

Inspector General (OIG) audits.

Single Audit Act (SAA) requirements 

What are the regulations governing SAA requirements?

The Single Audit Act (SAA) of 1984 established uniform guidelines for state and local governments receiving 

federal financial assistance. The 1984 Act was amended in July 1996, was revised on June 27, 2003 and again on

June 26, 2007, and is effective for fiscal years after December 31, 2003, to reflect revised audit criteria and 

reporting requirements. The Office of Management and Budget (OMB) issued final guidance for 2 CFR Part 200—

Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform 

Guidance) on December 26, 2013. This new guidance applies to all federal awards or funding increments 

awarded on or after December 26, 2014, and provides additional guidelines regarding the implementation of 

SAA requirements.

Who must have an SAA audit?

A recipient that expends $750,000 or more during the recipient's fiscal year in federal awards must have a single 

audit conducted in accordance with 2 CFR §200.514 (Scope of audit) except when it elects to have a programspecific audit conducted in accordance with 2 CFR §200.501(c). An auditee may be a recipient, a subrecipient, or 

a vendor. 

SAA audits are conducted annually unless a state or local government is required by constitution or statute, in 

effect on January 1, 1987, to undergo audits less frequently than annually. The primary objective of an SAA audit 

is to express opinions on the recipient’s financial statements, internal controls, major and non-major award 

programs, and compliance with government laws and regulations. Single Audits may also address specific 

compliance issues with respect to COPS Office award requirements.

In cases of continued inability or unwillingness to have an audit conducted in accordance with this part, federal 

agencies and pass-through entities must take appropriate action as provided in §200.338 (Remedies for 

noncompliance). 

These sanctions under A-133, Section 225 could include the following:

• Temporarily withholding cash payments pending correction of the deficiency by the nonfederal entity or 

more severe enforcement action by the federal awarding agency or pass-through entity

• Disallowing (that is, denying both use of funds and any applicable matching credit for) all or part of the cost 

of the activity or action not in compliance

• Wholly or partly suspending or terminating the federal award
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• Initiating suspension or debarment proceedings as authorized under 2 CFR part 180 and federal awarding 

agency regulations (or in the case of a pass-through entity, recommending such a proceeding be initiated 

by a federal awarding agency)

• Withholding further federal awards for the project or program

• Taking other remedies that may be legally available

Your SAA reports should not be sent to the COPS Office.

If the U.S. Department of Justice is your cognizant federal agency (see the Glossary of Terms on page 107), they 

should be sent to the Federal Audit Clearinghouse at:

Federal Audit Clearinghouse

Bureau of Census

1201 East 10th Street

Jeffersonville, IN 47132

The U.S. Department of Justice, Office of Justice Programs (OJP) serves as the liaison between recipients and 

auditors in the conduct of resolving and closing SAA audits. Questions and comments regarding SAA audits may 

be directed to the COPS Office Response Center at 800-421-6770.

Office of Inspector General (OIG) recipient audits 

What is the role of the OIG for award audits?

The OIG is a separate component of the U.S. Department of Justice and is independent of the COPS Office. The 

primary objective of OIG recipient audits is to assess compliance with award terms and conditions. OIG audits 

are designed to prevent fraud, waste, and abuse of federal funds. The OIG audit process promotes efficiency and 

effectiveness in the administration and implementation of awards by evaluating compliance with the terms and 

conditions of awards.

How are COPS Office awards selected for an OIG audit?

The OIG randomly selects awards to be audited or may conduct a COPS Office recipient audit in response to a 

referral that the OIG believes warrants further evaluation. The OIG also surveys DOJ award-making agencies on 

an annual basis to solicit input on suggested audit areas for the upcoming fiscal year. In most instances, 

however, the OIG generally selects awards to be audited based on a number of factors, including the 

geographical distribution of awards funded, award amount, population served, award status (active and 

expired), and type of award (hiring and non-hiring). As such, the fact that a recipient has been selected for an 

OIG audit is not necessarily indicative of a suspected concern or problem area. 

What are the steps in an OIG audit?

The COPS Office Grant Monitoring Division’s Audit Liaison Section serves as the liaison between recipients and 

the OIG’s Audit Division, which conducts the audit. The OIG steps in the audit process will determine the 

interactions between the OIG, the recipient, and the COPS Audit Liaison Section: 

• Call for award data. The OIG requests award documentation from the COPS Office.

• Entrance conference. The OIG schedules to meet with the recipient to gather documentation and conduct 

audit.
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• Draft audit report. The OIG reviews documentation and presents initial findings to the recipient and copies 

the COPS Office. The COPS Office interacts with the recipient to coordinate any repayments and/or policy or 

procedure documents to be submitted to the OIG before release of the Final Audit Report. 

• Final audit report. The OIG has completed its direct interaction with the recipient. The COPS Office directs 

the recipient to formulate a Corrective Action Plan to address recommendations (findings). As each 

recommendation is successfully addressed by the recipient, the COPS Office requests closure on the 

recommendation.

• Closing the audit. When all recommendations have been closed, the COPS Office requests closure on the 

audit from the OIG and notifies the recipient that the audit is closed.

If you have any questions regarding an OIG audit, please contact the COPS Office Grant Monitoring Division’s 

Audit Liaison Section at 800-421-6770. Questions and comments regarding the administration of your COPS CPD

award, not specifically related to an audit, should be referred to your COPS Office Program Manager. 

Typical audit findings

The OIG has typically reported the following audit findings pertaining to awards as a result of lack of proper 

documentation, poor business practices, or inadequate accounting and record keeping systems:

• Unallowable costs. Recipient incurred costs that were not approved in the original budget or a budget 

modification, were in excess of the approved budget, or were charged to the award after the expiration date 

and an award extension was not obtained.

• Unsupported costs. Specific award expenditures and reimbursements could not be supported by adequate 

documentation (including but not limited to receipts or purchase orders), that may have been allowable 

under the program, but for which no prior written approval was obtained from the COPS Office , or award 

expenditures were in excess of actual approved award costs.

• Lack of complete/timely programmatic and financial reporting. Recipient failed to submit required 

programmatic and financial reports in a timely manner and/or had inadequate record keeping systems.

• Funds to better use. Funds could be used more efficiently based on management actions such as

reductions in outlays; deobligation of funds; withdrawal; costs not incurred by implementing recommended 

improvements; and other identified savings.

• Questioned costs. Costs that are questioned by the auditor because of an audit finding which resulted from 

a violation or possible violation of a provision of law, regulation, award terms and conditions, or other 

document governing the use of federal funds; or because costs incurred appear unreasonable and do not 

reflect the actions a prudent person would take under the same circumstances; or because costs at the time 

of the audit are not supported by adequate documentation.

• Policy and procedure. Weaknesses are identified in a recipient’s accounting practices, fiscal stewardship, 

accuracy of data used in the development of the award applications, and/or inventory controls that led to 

the recommendation cited in the audit. The recipient is required to develop or revise policies and/or 

procedures consistent with their existing practices and submit to the COPS Office to forward to the OIG to 

close the recommendation.

After the final OIG audit report has been issued, the COPS Office Grant Monitoring Division will continue working 

as the liaison between your agency and the OIG to obtain closure on any audit findings. The COPS Office will 

issue a closure letter once all audit recommendations have been closed by the OIG. You must keep all 

documentation related to the audit for a period of three years following the audit’s closure.
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VII. Reports

As part of the CPD program, your agency will be required to submit quarterly Federal Financial Reports as well as 

quarterly Program Progress Reports. Awarded agencies should be prepared to track and report CPD award 

funding separately from other funding sources (including other COPS Office and federal awards) to ensure 

accurate financial and programmatic reporting on a timely basis. Your agency should ensure that you have 

financial internal controls in place to monitor the use of CPD funding and ensure that its use is consistent with 

the award terms and conditions. Good practices in this area would include written accounting practices, an 

accounting system that tracks all drawdowns and award expenditures, and the ability to track when awardfunded positions are filled or approved purchases are made. Failure to submit complete reports or submit them in a 

timely manner may result in the suspension and possible termination of your agency’s COPS Office award funding or 

other remedial actions.

Federal Financial Reports

Your agency is required to submit quarterly Federal Financial Reports (FFR) using Standard Form 425 (SF-425) 

within 30 days after the end of each calendar quarter. A final SF-425 will be due within 90 days after the end of 

the award period. This report reflects the actual cumulative federal expenditures incurred during the funding 

period and the remaining unobligated balance of federal funds. Under federal regulations, your agency is not 

permitted to draw down federal funding for costs incurred after the official award end date; however, you will 

have a 90-day grace period after the award end date during which you can draw down funds for eligible 

expenditures incurred before the award end date.

How do we file Federal Financial Reports?

All COPS Office awardees are required to submit quarterly Federal Financial Reports using the SF-425. Awardees 

are strongly encouraged to submit the quarterly SF-425 online. Visit the COPS Office website at 

https://portal.cops.usdoj.gov and select the “Account Access” link in the upper right corner to log in; once you 

are logged in, select “Applications” from the agency portal menu, click on the “SF-425” icon, and follow the 

instructions to complete and submit your reports. The online SF-425 requires the same reporting information as 

the paper version. The use of this online application enables authorized users to view past SF-425s, and allows 

them to file or amend the SF-425 for the current quarter.

When are Federal Financial Reports due? 

SF-425s for COPS Office awards must be submitted every quarter and no later than 30 days after the last day of 

each reporting quarter, as detailed in table 1: 

Table 1. Due dates of SF-425 by quarter

Reporting quarter SF-425 due date

January 1–March 31 April 30

April 1–June 30 July 30

July 1–September 30 October 30

October 1–December 31 January 30
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For your initial SF-425 submission, determine when the most recent SF-425 reporting period ended and 

complete an SF-425 to cover the period from the award start date to the end of that period. You are required to 

submit an SF-425 even if you have not spent any money or incurred any costs during a reporting period. The due 

dates for online filing of SF-425s are the same as for the submission of paper copies.

Example: 

If your award start date is 02-01-13 and the current date is 04-15-13, then your first SF-425 will be due no later 

than 04-30-13 and will cover the period 02-01-13 (award start date) through 03-31-13 (end of the most recent 

reporting quarter). This SF-425 must be on file with the COPS Office so that you can successfully complete a 

drawdown of funds through GPRS.

Awardees who do not submit SF-425s by the due date each quarter will be unable to draw down award funds 

until the report has been successfully submitted. The payment system contains a function which checks for SF425 delinquency and will reject a drawdown attempt if the SF-425 is not up to date. Subsequent e-mail, fax, 

and/or hard copy reminders may be sent to the awardee if the SF-425 is delinquent.

For general information concerning online filing of SF-425 reports, go to https://portal.cops.usdoj.gov or 

contact the COPS Office Response Center by phone at 800-421-6770 or by e-mail at AskCopsRC@usdoj.gov. 

If you need assistance in completing the SF-425, contact the COPS Office Response Center at 800-421-6770 or by 

e-mail at AskCopsRC@usdoj.gov and ask to be connected with the staff accountant that is assigned to your 

state or review the “Helpful Hints Guide for Completing the Federal Financial Report (SF-425)” at 

www.cops.usdoj.gov/pdf/SF-425_Helpful_Hints_Guide_5.9.13.pdf. 

How will award funds be monitored?

The COPS Office and designated representatives from the Office of the Chief Financial Officer, Office of Justice 

Programs monitor the financial aspects of your agency’s award through financial reports, on-site visits, officebased award reviews, meetings, telephone contacts, reports, audits, reviews of award change requests, and 

special request submissions.

Program Progress Reports

Quarterly Program Progress Reports and a Final Program Progress (Closeout) Report are required to be 

submitted directly to the COPS Office through the “Account Access” link of the COPS Office website at 

https://portal.cops.usdoj.gov. 

How do we file a Program Progress Report?

Please access the COPS Office website at https://portal.cops.usdoj.gov and click on the “Account Access” link 

at the top right side of the page. Once you are logged in, select “Applications” from the agency portal menu, 

click on the “Progress Report” icon, and follow the instructions to complete your report.

How do we obtain online access to complete the Program Progress Report?

If you do not have login access, you should contact your agency portal administrator to set up an account for 

you. 
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If you have a registered account but do not remember your password, you may reset your password by going to 

the agency portal homepage in “Account Access,” entering your e-mail address, and clicking on the “Forgot 

Password” link. If you do not have your user name or password, please contact the COPS Office Response Center 

by phone at 800-421-6770 (from Monday through Friday between 9:00 AM and 5:00 PM Eastern time) or by email at AskCopsRC@usdoj.gov. 

Do we need to request a Program Progress Report? 

No. The COPS Office will notify your agency directly when the report is due. A notification for submitting your 

quarterly Program Progress Report will be sent electronically in January, April, July, and October covering 

activities for the preceding calendar quarter. Notification for submitting your Final Program Progress (Closeout) 

Report will be sent to your agency in the month following your award end date.

When are Program Progress Reports due?

Program Progress Reports for COPS Office awards must be submitted every quarter and no later than 30 days 

after the last day of each reporting quarter, as detailed in table 2: 

Table 2. Due dates of Program Progress Reports by quarter

Reporting quarter Program Progress Report due date

January 31–March 31 April 30

April 1–June 30 July 30

July 1–September 30 October 30

October 1–December 31 January 30

What kind of information will these reports require? 

These reports will request information about the status of your award in terms of purchasing equipment, hiring 

personnel, delivering services, and progress in meeting milestones identified in the cooperative agreement, as 

well as general information about your agency. 

What if we make a mistake or need to modify the report after it is submitted? 

Recipients may need to make a change or may be asked by a subsequent COPS Office reviewer to make a 

correction to a submission. The recipient can update the submission by logging on to the COPS Office website or 

by calling the COPS Office Progress Report Team at 800-659-7379.

Will the data that we submit be publicly available?

Program Progress Reports submitted to the COPS Office may be reported publicly in response to a Freedom of 

Information Act (FOIA) request. 

If your agency has any questions regarding the submission of these required reports, please call the COPS Office 

Progress Report Team at 800-659-7379.
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Contact points to obtain technical assistance and report violations 

Any alleged violations, serious irregularities, or acts that may result in the use of public funds in a manner 

inconsistent with the Public Safety Partnership and Community Policing Act of 1994 or the purposes of this 

award may be reported to the U.S. Department of Justice. Furthermore, the COPS Office welcomes the 

opportunity to provide assistance regarding the implementation of award provisions to help ensure that federal 

award funds are spent responsibly. As such, the following contacts are provided to address noncompliance and 

technical assistance issues:

• If you suspect violations of a criminal nature, please contact the U.S. Department of Justice, Office of the 

Inspector General (OIG) at www.oig.justice.gov/hotline, OIG.hotline@usdoj.gov, or 800-869-4499.

• If you suspect award violations (not criminal in nature) related to the award conditions listed in this manual, 

please contact the COPS Office Grant Monitoring Division at 202-514-9202.

• If you have any questions or need assistance regarding your award, please contact your COPS Office

Program Manager at 800-421-6770.
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VIII. When the Award Period Has Ended

At the end of your agency’s CPD award period, the COPS Office is responsible for the closeout of your award. As 

part of this process, the COPS Office requires documentation demonstrating that your agency has met all of the 

programmatic and financial requirements of the award.

After the end of the award period, your agency will be asked to submit a final Federal Financial Report (SF-425) 

and any applicable final program reports.

Final Federal Financial Report (SF-425)

The final Federal Financial Report (SF-425) for your award is due to the COPS Office no later than 90 days after 

the end of the award period. The final report should reflect the total amount of allowable federal expenditures 

that were incurred during the life of the award, as well as the amount of unobligated funds remaining, if any. In 

addition, once you have completed your final drawdown, this report should reconcile with the total amount of 

funds drawn down by your agency.

When should all of the award monies be spent?

Award funds reflecting allowable project costs must be obligated before the end of the award period. Obligated 

funds cover monies spent and expenses for all approved items in the FCM that your agency has incurred but not 

yet paid. Your agency has up to 90 days after the end of the award period to request reimbursement for funds 

obligated.

Please be advised that 2 CFR § 200.343(a) requires recipients to submit final SF-425s and 2 CFR § 200.343(b) requires 

recipients to draw down the final reimbursement for expended funds within 90 days after the expiration of the award. 

In addition, be advised that failure to complete the drawdown of funds within the 90-day period following award 

expiration will result in the forfeiture of the remaining eligible balance.

It is possible that your agency may have excess award funds remaining in your account following the award 

period due to an overestimate of item costs during the award period. Your agency should review its records 

carefully to ensure that it draws down and expends only the amount required for actual costs incurred during 

the award period. Any excess unobligated or unspent funds should remain in your account, and will be 

deobligated during the closeout process.

Final Program Progress (Closeout) Report

After your award period has ended, your agency may be sent a final progress or closeout report from the COPS 

Office and asked to complete it. This report will serve as your agency’s final programmatic report on the award, 

and the information your agency provides in this report will be used to make a final assessment of your award 

progress.

Equipment disposition

Each recipient must use any equipment funded through a COPS Office award for approved award-related 

purposes and must retain the equipment for the life of the award. After the conclusion of the award period, 

property records must be maintained by the recipient. The records should include a description of the property; 
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a serial number or other identification number; the source of the property; the name of the person or entity that 

holds the title; the acquisition date and cost of the property; the percentage of federal participation in the cost of 

the property; the location, use, and condition of the property; and any ultimate disposition data, including the 

date of disposal and sale price of the property. A control system must be developed to ensure adequate 

safeguards to prevent loss, damage, or theft of the property.

When the award has expired and original or replacement equipment obtained under the award is no longer 

needed for the original project or for other activities currently or previously supported by a federal agency, 

disposition of the equipment shall be made as follows:

Items of equipment with a current per-unit fair market value of $5,000 or less may be retained, sold, or otherwise 

disposed of with no further obligation to the awarding agency.

Items of equipment with a current per-unit fair market value in excess of $5,000 may be retained or sold and the 

awarding agency is entitled to an amount calculated by multiplying the current market value or proceeds from 

sale by the awarding agency’s federal share in the cost of the original purchase. 

For more information, please see 2 CFR § 200.313. 
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IX. Conclusion

We hope that this manual has assisted you and your agency with your award questions. We welcome and 

encourage any comments you have regarding the COPS Office CPD Program and the materials we have 

developed for its administration. If you have specific comments regarding this manual or have any questions 

about your award, please call your COPS Office Program Manager or the COPS Office Response Center at 800-

421-6770.

Pursuant to Executive Order 13513, “Federal Leadership on Reducing Text Messaging While Driving,” the COPS 

Office encourages recipients of U.S. Department of Justice funds to adopt and enforce policies that ban text 

messaging while driving and to establish workplace safety policies to decrease crashes caused by distracted 

drivers.
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Appendices

Appendix A. List of source documents 

A. Primary Sources

Public Safety Partnership and Community Policing Act of 1994, 42 U.S.C. 3796dd et seq.

B. Secondary Sources

Code of Federal Regulations (CFR)/Office of Management and Budget (OMB):

2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal 

Awards) as adopted by the U.S. Department of Justice in 2 CFR § 2800.101

4 CFR Parts 101-105, U.S. Department of Justice/Government Accountability Office, “Joint Federal Claims 

Collections Standards”

5 CFR Part 1320, “Controlling Paperwork Burdens on the Public”

5 CFR Part 151, “Political Activity of State and Local Officers or Employees”

28 CFR Part 23, “Criminal Intelligence Systems Operating Policies”

28 CFR Part 61, “Procedures for Implementing the National Environmental Policy Act” 

28 CFR Part83, “Government-Wide Requirements for Drug-Free Workplaces (Grants)”

28 CFR Part 69, “New Restrictions on Lobbying”

31 CFR Part 205, ”Rules and Procedures for Efficient Federal-State Funds Transfers”

OMB Circular A-129, ”Policies for Federal Credit Programs and Non-Tax Receivables”

48 CFR Part 31 (Federal Acquisition Regulation), ”Contract Cost Principles and Procedures”

Executive Orders:

Executive Order 12291, “Regulations”

Executive Order 12372, 28 CFR Part 30, “Intergovernmental Review of Federal Programs”

Executive Order 12547, “Non-Procurement Debarments and Suspension”
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Appendix B. Assurances and Certifications 

Assurances

Several provisions of federal law and policy apply to all grant and cooperative agreement programs. The Office

of Community Oriented Policing Services (“COPS Office”) needs to secure your assurance that the applicant will

comply with these provisions. If you would like further information about any of these assurances, please

contact your state’s COPS Office Grant Program Specialist at 800-421-6770.

By signing this form, the applicant assures that it will comply with all legal and administrative requirements that

govern the applicant for acceptance and use of federal award funds. In particular, the applicant assures us of the 

following: 

1. It has been legally and officially authorized by the appropriate governing body (for example, mayor or city

council) to apply for this grant or cooperative agreement and that the persons signing the application and

these assurances on its behalf are authorized to do so and to act on its behalf with respect to any issues that

may arise during processing of this application.

2. It will comply with the provisions of federal law, which limit certain political activities of employees whose

principal employment is in connection with an activity financed in whole or in part with this grant or 

cooperative agreement. These restrictions are set forth in 5 U.S.C. § 1501, et seq.

3. It will comply with the minimum wage and maximum hours provisions of the Fair Labor Standards Act (29 

U.S.C. § 201, et seq.), if applicable.

4. It will establish safeguards, if it has not done so already, to prohibit employees from using their positions for

a purpose that is, or gives the appearance of being, motivated by a desire for private gain for themselves or

others, particularly those with whom they have family, business or other ties. In addition, it will disclose (in 

writing) to the COPS Office any potential conflict of interest arising during the course of performance of the 

grant or cooperative agreement award and also will require such written disclosures by any subrecipients.

5. As required by 42 U.S.C. § 3796dd-6, it will give the U.S. Department of Justice or the Comptroller General

access to and the right to examine records and documents related to the award.

6. It will comply with all requirements imposed by the U.S. Department of Justice as a condition or 

administrative requirement of the grant or cooperative agreement, including but not limited to: the

requirements of 2 C.F.R. Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit

Requirements for Federal Awards) as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101 ; 48

C.F.R. Part 31 (FAR Part 31) (Contract Cost Principles and Procedures); the applicable provisions of the

Omnibus Crime Control and Safe Streets Act of 1968, as amended; 28 C.F.R. Part 38 (Equal Treatment for 

Faith-Based Organizations); the applicable COPS application guide; the applicable COPS grant owner's

manual or award owner’s manual; and with all other applicable program requirements, laws, orders, or

regulations.

7. As required by 42 U.S.C. § 3796dd-1(c)(11), it will, to the extent practicable and consistent with applicable

law, seek, recruit and hire qualified members of racial and ethnic minority groups and qualified women in

order to further effective law enforcement by increasing their ranks within the sworn positions in the

agency.
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8. It will not (and will require any subgrantees, contractors, successors, transferees, and assignees not to), on

the grounds of race, color, religion, national origin, sex, disability, or age, unlawfully exclude any person

from participation in, deny the benefits of or employment to any person, or subject any person to

discrimination in connection with any programs or activities funded in whole or in part with federal funds.

These civil rights requirements are found in the non-discrimination provisions of Title VI of the Civil Rights

Act of 1964, as amended (42 U.S.C. § 2000d); the Omnibus Crime Control and Safe Streets Act of 1968, as 

amended (42 U.S.C. § 3789d); Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794); the

Age Discrimination Act of 1975 (42 U.S.C. § 6101, et seq.); Title IX of the Education Amendments of 1972, as 

amended (20 U.S.C. § 1681, et seq.); and the corresponding U.S. Department of Justice regulations

implementing those statutes at 28 C.F.R. Part 42 (subparts C, D, E, G, and I). It will also comply with Executive

Order 13279, Equal Protection of the Laws for Faith-Based and Community Organizations; Executive Order 

13559, Fundamental Principles and Policymaking Criteria for Partnerships With Faith-Based and Other 

Neighborhood Organizations; and the U.S. Department of Justice implementing regulations at 28 C.F.R. Part 

38. 

A. In the event that any court or administrative agency makes a finding of discrimination on grounds

of race, color, religion, national origin, gender, disability or age against the applicant after a due

process hearing, it agrees to forward a copy of the finding to the Office for Civil Rights, Office of

Justice Programs, 810 7th Street, NW, Washington, D.C. 20531.

B. It will comply with the federal regulations pertaining to the development and implementation of an 

Equal Employment Opportunity Plan (28 C.F.R. Part 42 subpart E). The requirements are as follows:

If your organization has fewer than fifty employees or receives an award of less than $25,000 or

is a nonprofit organization, a medical institution, an educational institution, or an Indian tribe, 

then it is exempt from the EEOP requirement. To claim the exemption, your organization must 

complete and submit Section A of the Certification Form, which is available online at 

http://www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf. If your organization is a government 

agency or private business and receives an award of $25,000 or more, but less than $500,000, 

and has fifty or more employees (counting both full- and part-time employees but excluding 

political appointees), then it has to prepare a Utilization Report (formerly called an EEOP Short 

Form), but it does not have to submit the report to the OCR for review. Instead, your 

organization has to maintain the Utilization Report on file and make it available for review on 

request. In addition, your organization has to complete Section B of the Certification Form and 

return it to the OCR. The Certification Form is available at 

http://www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf. If your organization is a government 

agency or private business and has received an award for $500,000 or more and has fifty or 

more employees (counting both full- and part-time employees but excluding political 

appointees), then it has to prepare a Utilization Report (formerly called an EEOP Short Form) 

and submit it to the OCR for review within sixty days from the date of this letter. For assistance 

in developing a Utilization Report, please consult the OCR's website at 

http://www.ojp.usdoj.gov/about/ocr/eeop.htm. In addition, your organization has to 

complete Section C of the Certification Form and return it to the OCR. The Certification Form is 

available at http://www.ojp.usdoj.gov/about/ocr/pdfs/cert.pdf. To comply with the EEOP 

requirements, you may request technical assistance from an EEOP specialist at the OCR by 

telephone at (202) 307-0690, by TTY at (202) 307-2027, or by e-mail at 

EEOsubmisson@usdoj.gov. 
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9. Pursuant to U.S. Department of Justice guidelines (June 18, 2002 Federal Register (Volume 67, Number 117,

pages 41455-41472)), under Title VI of the Civil Rights Act of 1964, it will ensure meaningful access to its 

programs and activities by persons with limited English proficiency.

10. It will ensure that any facilities under its ownership, lease or supervision which shall be utilized in the

accomplishment of the project are not listed on the Environmental Protection Agency’ (EPA) list of Violating

Facilities and that it will notify us if advised by the EPA that a facility to be used in this grant is under

consideration for such listing by the EPA..

11. If the applicant’s state has established a review and comment procedure under Executive Order 12372 and

has selected this program for review, it has made this application available for review by the state Single

Point of Contact.

12. It will submit all surveys, interview protocols, and other information collections to the COPS Office for 

submission to the Office of Management and Budget for clearance under the Paperwork Reduction Act of

1995 if required.

13. It will comply with the Human Subjects Research Risk Protections requirements of 28 C.F.R. Part 46 if any

part of the funded project contains non-exempt research or statistical activities which involve human

subjects and also with 28 C.F.R. Part 22, requiring the safeguarding of individually identifiable information

collected from research participants.

14. Pursuant to Executive Order 13043, it will enforce on-the-job seat belt policies and programs for employees

when operating agency-owned - or - rented or personally-owned vehicles.

15. As required by 42 U.S.C. § 3796dd-3(a), it will not use COPS Office funds to supplant (replace) state, local, or

Bureau of Indian Affairs funds that otherwise would be made available for the purposes of this grant, as 

applicable.

16. If the awarded grant contains a retention requirement, it will retain the increased officer staffing level or the

increased officer redeployment level, as applicable, with state or local funds for a minimum of 12 months

following expiration of the grant period.

17. It will not use any federal funding directly or indirectly to influence in any manner a Member of Congress, a 

jurisdiction, or an official of any government, to favor, adopt, or oppose, by vote or otherwise, any

legislation, law ratification, policy or appropriation whether before or after the introduction of any bill,

measure, or resolution proposing such legislation, law, ratification, policy or appropriation as set forth in the

Anti- Lobby Act, 18 U.S.C. § 1913.

18. In the event that a portion of grant reimbursements are seized to pay off delinquent federal debts through

the Treasury Offset Program or other debt collection process, it agrees to increase the nonfederal share (or, if

the awarded grant does not contain a cost sharing requirement, contribute a nonfederal share) equal to the

amount seized in order to fully implement the grant project.
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False statements or claims made in connection with COPS Office grants or cooperative agreements may result in 

fines, imprisonment, debarment from participating in federal grants or contracts, and/or any other remedy

available by law.

I certify that the assurances provided are true and accurate to the best of my knowledge.

Elections or other selections of new officials will not relieve the awardee of its obligations under this award. 

__________________________________________ ___________________________

Signature of Law Enforcement Executive/Agency Executive Date

(For your electronic signature, please type in your name) 

______________________________________________ _____________________________

Signature of Government Executive/Financial Official Date

(For your electronic signature, please type in your name)
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Certifications

Regarding Lobbying; Debarment, Suspension and Other Responsibility Matters; Federal Taxes and 

Assessments; Drug-Free Workplace Requirements; and Coordination with Affected Agencies.

Although the U.S. Department of Justice has made every effort to simplify the application process, other 

provisions of federal law require us to seek your agency’s certification regarding certain matters. Applicants 

should carefully review the statutes and regulations cited below and the instructions for certification to 

understand the requirements and whether they apply to a particular applicant. Signing this form complies with 

the certification and notice requirements under 28 C.F.R. Part 69 “New Restrictions on Lobbying”; 2 C.F.R. Part

2867 “Nonprocurement Debarment and Suspension”; 2 C.F.R. Part 200 “Uniform Administrative Requirements, 

Cost Principles, and Audit Requirements for Federal Awards”; the general provisions in the applicable 

Appropriations Act; 28 C.F.R. Part 83 “Government-Wide Requirements for Drug-Free Workplace (Grants)”; and 

the Public Safety Partnership and Community Policing Act of 1994.. The certifications shall be treated as a 

material representation of fact upon which reliance will be placed when the U.S. Department of Justice 

determines to award the covered grant.

1. Lobbying

As required by 31 U.S.C. § 1352, implemented at 28 C.F.R. Part 69, for persons entering into a grant or 

cooperative agreement over $100,000, and 2 C.F.R. § 200.450 as adopted by the U.S. Department of Justice 

in 2 C.F.R. § 2800.101, the applicant certifies to the following:

A. No federal appropriated funds have been paid or will be paid, by or on behalf of the undersigned, 

to any person for influencing or attempting to influence an officer or employee of any agency, a 

member of Congress, an officer or employee of Congress, or an employee of a member of Congress 

in connection with the making of any federal grant; the entering into of any cooperative 

agreement; or the extension, continuation, renewal, amendment or modification of any federal 

grant or cooperative agreement.

B. If any funds other than federal appropriated funds have been paid or will be paid to any person for 

influencing or attempting to influence an officer or employee of any agency, a member of 

Congress, an officer or employee of Congress, or an employee of a member of Congress in 

connection with this federal grant or cooperative agreement, the undersigned shall complete and 

submit Standard Form - LLL, “Disclosure of Lobbying Activities,” in accordance with its instructions. 

C. If applicant is a nonprofit organization or an institution of higher education, it will comply with the 

additional lobbying restrictions set forth in 2 C.F.R. § 200.450(c) as adopted by the U.S. Department 

of Justice in 2 C.F.R. § 2800.101.

D. The undersigned shall require that the language of this certification be included in the award 

documents for all subawards at all tiers (including subgrants, contracts under grants and 

cooperative agreements, and subcontracts) and that all sub-recipients shall certify and disclose 

accordingly.
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2. Debarment, Suspension and Other Responsibility Matters (Direct Recipient)

Pursuant to Executive Order 12549, Debarment and Suspension, as implemented at 2 C.F.R. Part 2867, for 

prospective participants in primary covered transactions, as defined at 2 C.F.R. § 2867.20(a), and other 

requirements, the applicant certifies that it and its principals:

A. Are not presently debarred, suspended, proposed for debarment, declared ineligible, sentenced to 

a denial of federal benefits by a state or federal court, or voluntarily excluded from covered 

transactions by any federal department or agency;

B. Have not within a three-year period preceding this application been convicted of a felony criminal 

violation under any federal law, or been convicted or had a civil judgment rendered against them 

for commission of fraud or a criminal offense in connection with obtaining, attempting to obtain, or 

performing a public (federal, state or local) or private agreement or transaction; violation of federal 

or state antitrust statutes or commission of embezzlement, theft, forgery, bribery, falsification or 

destruction of records, making false statements, tax evasion or receiving stolen property, making 

false claims, or obstruction of justice, or commission of any offense indicating a lack of business 

integrity or business honesty that seriously and directly affects your present responsibility;

C. Are not presently indicted for or otherwise criminally or civilly charged by a governmental entity 

(federal, state or local) with commission of any of the offenses enumerated in paragraph (B) of this 

certification; and 

D. Have not within a three-year period preceding this application had one or more public transactions 

(federal, state or local) terminated for cause or default.

3. Mandatory Disclosure

Pursuant to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal 

Awards, 2 C.F.R. § 200.113 as adopted by the U.S. Department of Justice in 2 C.F.R. § 2800.101, the applicant 

certifies that it:

A. Has not violated any federal criminal law involving fraud, bribery, or gratuity that may potentially 

affect the federal grant or cooperative agreement; 

B. Shall timely disclose in writing to the federal awarding agency or pass-through entity, as applicable, 

any violation of federal criminal law involving fraud, bribery, or gratuity that may potentially affect 

the federal grant or cooperative agreement; and

C. Shall require that the language of this certification be included in the award documents for all 

subawards (including subgrants and cooperative agreements) and shall require all subrecipients 

certify and disclose accordingly. 

4. Federal Taxes and Assessments

A. If applicable, an applicant who receives an award in excess of $5,000,000 certifies that, to the best of

its knowledge and belief, the applicant has filed all federal tax returns required during the three 

years preceding the certification, has not been convicted of a criminal offense under the Internal 

Revenue Code of 1986, and has not, more than 90 days prior to certification, been notified of any 

unpaid federal tax assessment for which the liability remains unsatisfied, unless the assessment is 

the subject of an installment agreement or offer in compromise that has been approved by the 

Internal Revenue Service and is not in default, or the assessment is the subject of a non-frivolous 

administrative or judicial proceeding.
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B. The applicant certifies that it does not have any unpaid federal tax liability that has been assessed, 

for which all judicial and administrative remedies have been exhausted or have lapsed, and that is 

not being paid in a timely manner pursuant to an agreement with the authority responsible for 

collecting the tax liability.

5. Drug-Free Workplace 

As required by the Drug-Free Workplace Act of 1988 (41 U.S.C. 8103), and implemented at 28 C.F.R. Part 83, 

for recipients (other than individuals), as defined at 28 C.F.R. § 83.660 – 

A. The applicant certifies that it will, or will continue to, provide a drug- free workplace by doing the 

following:

(i) Publishing a statement notifying employees that the unlawful manufacture, distribution, 

dispensing, possession or use of a controlled substance is prohibited in the grantee’s 

workplace and specifying the actions that will be taken against employees for violation of such 

prohibition;

(ii) Establishing an on-going drug-free awareness program to inform employees about – 

(a) the dangers of drug abuse in the workplace;

(b) the grantee’s policy of maintaining a drug-free workplace;

(c) any available drug counseling, rehabilitation and employee assistance programs; and

(d) the penalties that may be imposed upon employees for drug-abuse violations occurring in 

the workplace; 

(iii) Making it a requirement that each employee to be engaged in the performance of the grant be 

given a copy of the statement required by paragraph (i);

(iv) Notifying the employee in the statement required by paragraph (i) that, as a condition of 

employment under the grant, the employee will – 

(a) abide by the terms of the statement; and

(b) notify the employer in writing of his or her conviction for a violation of a criminal drug 

statute occurring in the workplace no later than five calendar days after such conviction; 

(v) Notifying the agency in writing within 10 calendar days after receiving notice under 

subparagraph (iv)(b) from an employee or otherwise receiving actual notice of such conviction. 

Employers of convicted employees must provide notice, including position title, to: COPS 

Office, 145 N Street, NE, Washington, D.C. 20530. Notice shall include the identification 

number(s) of each affected grant;

(vi) Taking one of the following actions within 30 calendar days of receiving notice under 

subparagraph (iv)(b) with respect to any employee who is so convicted – 

(a) Taking appropriate personnel action against such an employee, up to and including 

termination, consistent with the requirements of the Rehabilitation Act of 1973, as 

amended; or

(b) Requiring such employee to participate satisfactorily in a drug abuse assistance or 

rehabilitation program approved for such purposes by a federal, state or local health, law 

enforcement or other appropriate agency;
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(vii) Making a good faith effort to continue to maintain a drug-free workplace through 

implementation of paragraphs (i), (ii), (iii), (iv), (v), and (vi).

B. The applicant further certifies that it will identify all known workplaces under each COPS Office 

award, keep the identification documents on file, and make them available for inspection upon 

request by the U.S. Department of Justice officials or their designated representatives. 

6. Coordination

As required by 42 U.S.C. § 3796dd-1(c)(5) of the Public Safety Partnership and Community Policing Act of 

1994, applicants must certify that there has been appropriate coordination with all agencies that may be 

affected by the applicant’s grant proposal if approved. Affected agencies may include, among others, the 

Office of the United States Attorney, state or local prosecutors, or correctional agencies. The applicant 

certifies that there has been appropriate coordination with all affected agencies. 

 Where the applicant is unable to certify to any of the statements in this Certifications form, he or she shall attach an 

explanation to this application regarding the particular statement that cannot be certified. Please check the box if an 

explanation is attached to this application. Please note that the applicant is still required to sign the Certifications 

form to certify to all the other applicable statements.

False statements or claims made in connection with COPS Office grants or cooperative agreements may result in 

fines, imprisonment, debarment from participating in federal grants or contracts, and/or any other remedy 

available by law.

I certify that the assurances provided are true and accurate to the best of my knowledge.

Elections or other selections of new officials will not relieve the grantee entity of its obligations under this grant.

__________________________________________________ ___________________________

Signature of Law Enforcement Executive/Agency Executive Date

(For your electronic signature, please type in your name) 

______________________________________________ ______________________________

Signature of Government Executive/Financial Official Date

(For your electronic signature, please type in your name)
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Appendix C. Community policing defined

Community policing is a philosophy that promotes organizational strategies that support the systematic use of 

partnerships and problem-solving techniques, to proactively address the immediate conditions that give rise to 

public safety issues such as crime, social disorder, and fear of crime. 

Community policing is composed of three key components:

1. Community partnerships

2. Organizational transformation

3. Problem solving

Community partnerships 

Community partnerships are collaborative partnerships between law enforcement agencies and the individuals 

and organizations they serve to develop solutions to problems and increase trust in police.

Community policing, recognizing that police rarely can solve public safety problems alone, encourages 

interactive partnerships with relevant stakeholders. The range of potential partners is large, and these 

partnerships can be used to accomplish the two interrelated goals of developing solutions to problems through 

collaborative problem solving and improving public trust. The public should play a role in prioritizing and 

addressing public safety problems.

Other government agencies

Law enforcement organizations can partner with a number of other government agencies to identify 

community concerns and offer alternative solutions. Examples of agencies include legislative bodies, 

prosecutors, probation and parole departments, public works departments, neighboring law enforcement 

agencies, health and human services departments, child support services, ordinance enforcement, and schools.

Community members or groups

Individuals who live, work, or otherwise have an interest in the community—volunteers, activists, formal and 

informal community leaders, residents, visitors and tourists, and commuters—are a valuable resource for 

identifying community concerns. These factions of the community can be engaged in achieving specific goals at 

town hall meetings, neighborhood association meetings, decentralized offices or storefronts in the community, 

and team beat assignments.

Nonprofits or service providers

Advocacy and community-based organizations that provide services to the community and advocate on its 

behalf can be powerful partners. These groups often work with or are composed of individuals who share 

common interests and can include such entities as victims groups, service clubs, support groups, issue groups, 

advocacy groups, community development corporations, and the faith community.
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Private businesses

For-profit businesses also have a great stake in the health of the community and can be key partners because 

they often bring considerable resources to bear in addressing problems of mutual concern. Businesses can help 

identify problems and provide resources for responses, often including their own security technology and 

community outreach. The local chamber of commerce and visitor centers can also assist in disseminating 

information about police-business partnerships and initiatives, and crime prevention practices.

Media

The media represent a powerful mechanism by which to communicate with the community. They can assist with 

publicizing community concerns and available solutions, such as services from government or community 

agencies or new laws or codes that will be enforced. In addition, the media can have a significant impact on 

public perceptions of the police, crime problems, and fear of crime.

Organizational transformation 

Organizational transformation is the alignment of organizational management, structure, personnel, and 

information systems to support community partnerships and proactive problem-solving efforts.

The community policing philosophy focuses on the way that departments are organized and managed and how 

the infrastructure can be changed to support the philosophical shift behind community policing. It encourages 

the application of modern management practices to increase efficiency and effectiveness. Community policing 

emphasizes changes in organizational structures to institutionalize its adoption and infuse it throughout the 

entire department, including the way it is managed and organized, its personnel, and its technology.

Agency management

Under the community policing model, police management infuses community policing ideals throughout the 

agency by making a number of critical changes in climate and culture, leadership, formal labor relations, 

decentralized decision-making and accountability, strategic planning, policing and procedures, organizational 

evaluations, and increased transparency.

Climate and culture

Changing the climate and culture means supporting a proactive orientation that values systematic problem 

solving and partnerships. Formal organizational changes should support the informal networks and 

communication that take place within agencies to support this orientation.

Leadership

Leaders serve as role models for taking risks and building collaborative relationships to implement community 

policing and they use their position to influence and educate others about it. Leaders, therefore, must constantly 

emphasize and reinforce community policing’s vision, values, and mission within their organization and support 

and articulate a commitment to community policing as the predominant way of doing business.
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Labor relations

If community policing is going to be effective, police unions and similar forms of organized labor must be a part 

of the process and function as partners in the adoption of the community policing philosophy. Including labor 

groups in agency changes can ensure support for the changes that are imperative to community policing 

implementation.

Decision making 

Community policing calls for decentralization both in command structure and decision-making. Decentralized 

decision making allows front-line officers to take responsibility for their role in community policing. When an 

officer is able to create solutions to problems and take risks, he or she ultimately feels accountable for those 

solutions and assumes a greater responsibility for the well-being of the community. Decentralized decision 

making involves flattening the hierarchy of the agency, increasing tolerance for risk taking in problem-solving 

efforts, and allowing officers discretion in handling calls. In addition, providing sufficient authority to coordinate 

various resources to attack a problem and allowing officers the autonomy to establish relationships with the 

community will help define problems and develop possible solutions.

Strategic planning

The department should have a written statement reflecting a department-wide commitment to community 

policing and a plan that matches operational needs to available resources and expertise. If a strategic plan is to 

have value, the members of the organization should be well-versed in it and be able to give examples of their 

efforts that support the plan. Components such as the organization’s mission and values statement should be 

simple and communicated widely. 

Policies

Community policing affects the nature and development of department policies and procedures to ensure that 

community policing principles and practices have an effect on activities on the street. Problem solving and 

partnerships, therefore, should become institutionalized in policies, along with corresponding sets of 

procedures, where appropriate.

Organizational evaluations

In addition to the typical measures of police performance (arrests, response times, tickets issued, and crime 

rates) community policing calls for a broadening of police outcome measures to include greater community 

satisfaction, less fear of crime, the alleviation of problems, and improvement in quality of life. Community 

policing calls for a more sophisticated approach to evaluation—one that looks not only at measured outcomes, 

but also at how feedback information is used.

Transparency

Community policing involves decision-making processes that are more open than traditional policing. If the 

community is to be a full partner, the department needs mechanisms for readily sharing relevant information on 

crime and social disorder problems and police operations with the community.
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Organizational structure

It is important that the organizational structure of the agency ensure that local patrol officers have decisionmaking authority and are accountable for their actions. This can be achieved through long-term assignments, 

the development of officers who are generalists, and using special units appropriately.

Geographic deployment of patrol officers and specialized components

With community policing, there is a shift to the long-term assignment of officers to specific neighborhoods or 

areas. Geographic deployment of patrol officers and specialized components can help enhance customer service 

and facilitate more contact between police and citizens, thus establishing strong relationships and mutual 

accountability. Patrol beat boundaries should be aligned to neighborhood boundaries to enhance officers’ 

understanding of communities within their patrol areas and to build trust within the community. Other 

community policing partners should become familiar with both the patrol officers and community policing 

officers assigned within each patrol beat to coordinate government and nongovernment community policing 

activities.

Despecialization

To achieve community policing goals, the culture of policing should strive to have officers have to be able to 

handle multiple responsibilities and take a team approach to collaborative problem solving and partnering with 

the community. Community policing encourages its adoption agency-wide, not just by special units, although 

there may be a need for specialist units that are tasked with identifying and solving particularly complex 

problems or managing complex partnerships.

Resources (time, finances, and people)

Agencies have to devote the necessary human and financial resources and the investment of time to support 

community policing to ensure that problem-solving efforts are robust and that partnerships are sustained and 

effective.

Personnel

The principles of community policing need to be infused throughout the entire personnel system of an agency 

including recruitment, hiring, selection, and retention of all law enforcement agency staff, from sworn officers to 

civilians and volunteers. Personnel evaluations, supervision, and training must also be aligned with the agencies’ 

community policing values.

Recruitment, hiring, and selection

Agencies need a systematic means of incorporating community policing elements into their recruitment, 

selection, and hiring processes. Job descriptions should recognize community policing and problem-solving 

responsibilities and encourage the recruitment of officers who have a spirit of service, not just a spirit of 

adventure. A community policing agency must also thoughtfully examine where it looks for recruits, whom it is 

recruiting and hiring, and what is being tested. Agencies are also encouraged to seek community involvement in

this process through the identification of competencies and participation in review boards.
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Personnel supervision/evaluations

Supervisors must tie performance evaluations to community policing principles and activities that are 

incorporated into job descriptions. Performance, reward, and promotional procedures should support sound 

problem-solving activities, proactive policing, community collaboration, and citizen satisfaction with police 

services.

Training

Training at all levels—academy, field, and in-service—must support community policing principles and tactics. It 

also needs to encourage creative thinking, a proactive orientation, communication and analytical skills, and 

techniques for dealing with quality-of-life concerns and maintaining order. Officers can be trained to identify 

and correct conditions that could lead to crime, raise public awareness, and engage the community in finding 

solutions to problems. Field training officers and supervisors need to learn how to encourage problem solving 

and help officers learn from other problem-solving initiatives. Until community policing is institutionalized 

within the organization, training in its fundamental principles will need to take place regularly.

Information technology systems 

Community policing is highly information-intensive, and technology plays a central role in providing ready 

access to quality information. Accurate and timely information makes problem-solving efforts more effective 

and ensures that officers are informed about the crime and community conditions of their patrol beat. In 

addition, technological enhancements can greatly assist with accessing information to provide vital resources, 

improving two-way communication with citizens, and developing agency accountability systems and 

performance outcome measures.

Communication / access to data

Technology provides agencies with an important forum by which to communicate externally with the public 

and internally within their organization. To communicate with the public, community policing encourages 

agencies to develop two-way communication systems through the Internet that allow for online reports; reverse 

911; e-mail alerts; Internet social media discussion forums; and feedback on interactive applications (such as 

surveys and geographical information), thereby creating open, ongoing dialogues and increasing transparency.

Technology encourages effective internal communication through memoranda, reports, newsletters, e-mail and 

enhanced incident reporting, dispatch functions, and communications interoperability with other entities for 

more efficient operations. Community policing also encourages the use of technology to develop accountability 

and performance measurement systems that are timely and contain accurate metrics and a broad array of 

measures and information.

Community policing encourages the use of technology to provide officers with ready access to timely 

information on crime and community characteristics within their beats, either through laptop computers in their 

patrol cars or through personal data devices. In addition, technology can support crime/problem analysis 

functions by enabling agencies to gather more detailed information about offenders, victims, crime locations, 

and quality-of-life concerns, and to further enhance analysis.
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SAFECOM guidance

The U.S. Department of Homeland Security Office of Emergency Communications, in coordination with various 

stakeholder groups, develops the annual SAFECOM Guidance on Emergency Communications Grants. The 

guidance provides recommendations to award recipients seeking funding for interoperable emergency 

communications projects, including allowable costs, items to consider when funding emergency 

communications projects, awards management best practices for emergency communications awards, and 

information on standards that ensure greater interoperability. The guidance is intended to ensure that federally 

funded investments are compatible and support national goals and objectives for improving interoperability 

nationwide. Recipients (including sub-recipients) that are using CPD funds to support emergency 

communications activities should comply with the latest version of SAFECOM Guidance, including provisions on 

technical standards that ensure and enhance interoperable communications. The most recent version of 

SAFECOM guidance is available at www.safecomprogram.gov/grant/Default.aspx. 

Quality and accuracy of data

Information is only as good as its source; therefore, it is not useful if it is of questionable quality and accuracy. 

Community policing encourages agencies to put safeguards in place to ensure that information from various 

sources is collected in a systematic fashion and entered into central systems that are linked to one another and 

checked for accuracy so that it can be used effectively for strategic planning, problem solving, and performance 

measurement.

Problem solving

The process of engaging in the proactive and systematic examination of identified problems to develop and 

evaluate effective responses.

Community policing emphasizes proactive problem solving in a systematic and routine fashion. Rather than 

responding to crime only after it occurs, community policing encourages agencies to proactively develop 

solutions to the immediate underlying conditions contributing to public safety problems. Problem solving must 

be infused into all police operations and guide decision-making efforts. Agencies are encouraged to think 

innovatively about their responses and view making arrests as only one of a wide array of potential responses. A 

major conceptual vehicle for helping officers to think about problem solving in a structured and disciplined way 

is the SARA (scanning, analysis, response, and assessment) problem-solving model.

Scanning: Identifying and prioritizing problems

The objectives of scanning are to identify a basic problem, determine the nature of that problem, determine the 

scope of seriousness of the problem, and establish baseline measures. An inclusive list of stakeholders for the 

selected problem is typically identified in this phase. A problem can be thought of as two or more incidents 

similar in one or more ways and that is of concern to the police and the community. Problems can be a type of 

behavior, a place, a person or persons, a special event or time, or a combination of any of these. The police, with 

input from the community, should identify and prioritize concerns.
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Analysis: Researching what is known about the problem

Analysis is the heart of the problem-solving process. The objectives of analysis are to develop an understanding 

of the dynamics of the problem, develop an understanding of the limits of current responses, establish 

correlation, and develop an understanding of cause and effect. As part of the analysis phase, it is important to 

find out as much as possible about each aspect of the crime triangle by asking who?, what?, when?, where?, 

how?, why?, and why not? about the victim, offender, and crime location.

Response: Developing solutions to bring about lasting reductions in the number and extent of 

problems

The response phase of the SARA model involves developing and implementing strategies to address an 

identified problem by searching for strategic responses that are both broad and uninhibited. The response 

should follow logically from the knowledge learned during the analysis and should be tailored to the specific 

problem. The goals of the response can range from totally eliminating the problem through substantially 

reducing the problem or reducing the amount of harm caused by the problem to improving the quality of 

community cohesion.

Assessment: Evaluating the success of the responses

Assessment attempts to determine if the response strategies were successful by understanding if the problem 

declined and if the response contributed to the decline. This information not only assists the current effort but 

also gathers data that build knowledge for the future. Strategies and programs can be assessed for process, 

outcomes, or both. If the responses implemented are not effective, the information gathered during analysis 

should be reviewed. New information may have to be collected before new solutions can be developed and 

tested. The entire process should be viewed as circular rather than linear, meaning that additional scanning, 

analysis, or responses may be required.

Using the crime triangle to focus on immediate conditions (victim/offender/ location)

To understand a problem, many problem solvers have found it useful to visualize links among the victim, 

offender, and location (the crime triangle) and those factors that could have an impact on them, for example, 

capable guardians for victims (e.g., security guards, teachers, and neighbors), handlers for offenders (e.g., 

parents, friends, and probation), and managers for locations (e.g., business merchants, park employees, and 

motel clerks). Rather than focusing primarily on addressing the root causes of a problem, the police focus on the 

factors that are within their reach, such as limiting criminal opportunities and access to victims, increasing 

guardianship, and associating risk with unwanted behavior.
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Appendix D. Sole source justification facts 

What is “sole source” procurement?

Sole source or procurement by noncompetitive proposals is procurement through solicitation of a proposal 

from only one source. Sole source procurements must adhere to the standards set forth in the Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR § 200.318, as 

adopted by the U.S. Department of Justice in 2 CFR § 2800.101.

When is sole source approval required by the COPS Office? 

An award recipient must request written approval from the COPS Office for sole source procurements in excess 

of $150,000 prior to purchasing equipment, technology, or services; obligating funding for a contract; or 

entering into a contract with award funds. For the purchase of equipment, technology, or services under a COPS 

Office award, recipients must use their own documented procurement procedures that reflect applicable state 

and local laws and regulations, as long as those requirements conform to the federal procurement requirements 

set forth in 2 CFR § 200.320 as adopted by the U.S. Department of Justice in 2 CFR § 2800.101. A sole source 

justification request should be submitted if a recipient determines that the award of a contract through a 

competitive process is infeasible. The COPS Office may authorize a noncompetitive proposal if one or more of 

the following circumstances apply:

• The item/service is available only from one source. 

• The public exigency or emergency for the requirement will not permit a delay resulting from competitive 

solicitation.

• The COPS Office authorizes noncompetitive proposals in response to a written request from the recipient.

• Competition is determined inadequate after solicitation of a number of sources.

What documentation must be submitted to the COPS Office for sole source approval?

Requests for sole source procurements of equipment, technology, or services in excess of $150,000 must be 

submitted to the COPS Office in writing certifying that the award of the contract through full and open 

competition is infeasible.

The outline below may be helpful in preparing your agency’s sole source request and ensuring that all of the 

necessary information is included. 

The sole source request must be signed and submitted on recipient department letterhead and must include the 

agency’s ORI number and the award number for which the approval is being sought. The request should also 

include the following information:
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Section I. A brief description of the project, the amount to be designated for the sole source 

procurement, and the purpose of the contract 

Section II. (a) An explanation as to why it is necessary to contract in a noncompetitive manner and (b) 

Which one (or more) of the four circumstances identified below applies to the procurement transaction 

(include supporting information as identified below under the applicable section(s)):

1. If the item or service is available only from one source, please include the following:

• Uniqueness of items or services to be procured from the proposed contractor or 

vendor (compatibility, patent issues, etc.) 

• How the agency determined that the item or service is only available from one source 

(e.g., market survey results, independent agency research, patented or proprietary 

system, etc.) 

• Explanation of need for contractor’s expertise linked to the current project (e.g., 

knowledge of project management, responsiveness, experience of contractor 

personnel, prior work on earlier phases of project)

• Any additional information that would support the case

2. If the public exigency or emergency for the requirement will not permit a delay resulting 

from competitive solicitation, please include the following:

• When the contractual coverage is required by your department and why

• Impact on project if deadline/dates are not met

• How long it would take an alternate contractor to reach the same required level of 

competence (equate to dollar amounts, if desired)

• Any additional information that would support the case

3. The COPS Office authorizes noncompetitive proposals in response to a written request 

from the recipient.

4. If competition is determined inadequate after solicitation of a number of sources, please 

include the following:

• Results of a market survey to determine competition availability; if no survey is 

conducted, please explain why not

• Any additional information that would support the case 

Section III. A declaration that this action/choice is in the best interest of the agency. 

Failure to provide all of the necessary information will delay the processing of your request. Your 

agency will be contacted if any of the identified information is missing or if additional supporting 

information is required. If the COPS Office determines that the request does not meet the standards set 

forth above, the request will be denied.
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Please be advised that conflicts of interest are prohibited under the procurement standards set forth in 2 C.F.R. 

§200.318(c). In addition, program funds should not be awarded to any party that is debarred or suspended from 

participation in federal assistance programs.

If you have any questions regarding the federal requirements that guide procurement procedures, please 

contact your Grant Program Specialist or Program Manager at 800-421-6770.

Contact the COPS Office

If you have any questions regarding the federal requirements that guide procurement procedures, please 

contact your COPS Office Program Manager. 

For more information about COPS Office programs and resources, please call the COPS Office Response Center 

at 800-421-6770 or visit the COPS Office online at www.cops.usdoj.gov. 
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Appendix E. Conference reporting requirements

The sample submission forms on the following pages show the required reporting categories for conference 

expenses.
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Appendix F. Consultant/contractor rate information sheet

Consultant expenses and contracts include goods or services that directly contribute to the implementation or 

enhancement of the project. The use of a consultant should be more economical than direct employment. 

Compensation for individual consultant services procured under a COPS Office award must be reasonable and 

allocable in accordance with Office of Management and Budget (OMB) cost principles and consistent with that 

paid for similar services in the marketplace. 

Recipient guidelines on consultant rate approval requests

Compensation for individual consultant services procured under a COPS Office award must be reasonable and 

allocable in accordance with 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit 

Requirements for Federal Awards) and 48 CFR Part 31 (FAR Part 31) (Contract Cost Principles and Procedures), as 

applicable. 

Unless otherwise approved by the COPS Office, approved consultant rates will be based on the salary a 

consultant receives from his or her primary employer, as applicable, up to $650 per day. If individuals receive 

fringe benefits from their primary employer, such fringe benefit costs should not be included in the calculation 

of consultant rates. For consultant or contractor rates which exceed $650 per day, the COPS Office requires 

written justification if the consultants or contractors are hired through a noncompetitive bidding process. The 

recipient agency must provide justification for any such rate in excess of $650 per day and receive COPS Office

approval of that rate before drawing down award funds. Any jurisdiction that does not provide sufficient written 

justification will be limited to $650 per day for each consultant or contractor. Please note that this does not 

mean that the rate can or should be $650 for all consultants. 

Note: Consultant and contractor daily rates do not include travel or subsistence, but may include preparation, 

evaluation, and travel time.

Guidance for requesting a consultant rate based on employment

Consultants associated with educational institutions (including state-run educational institutions). If 

representing an academic institution, the maximum rate of compensation that will be allowed is the consultant’s 

academic salary projected for 12 months, divided by 260. These individuals normally receive fringe benefits that

include sick leave for a full 12-month period, even though they may only work nine months per year in their 

academic positions. This does not apply to individuals providing consultant work outside of their academic 

commitments. In such cases, the rate of compensation will be based on reasonable cost principles and requires 

documentation supporting the requested rate.

Consultants employed by state and local government. Compensation for these consultants will be allowed 

only when the unit of government will not provide these services without cost. If a state or local government 

employee is providing services under a federal award and is representing his or her agency without pay from its 

respective unit of government, the rate of compensation is not to exceed the daily salary rate for the employee 

paid by the unit of government. If the state or local government employee is providing services under a federal 

award and is not representing his or her agency, the rate of compensation is based on the necessary and 

reasonable cost principles. Please note that under the nonsupplanting requirement of the COPS Office statute, 

COPS Office award funds may not be used to supplant (replace) local funding which otherwise would have been 
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spent on consultants employed by state or local government. The statute bars federal funding of existing 

consultants and also of newly hired consultants that a community is committed to fund in the absence of a 

COPS Office award. 

Consultants employed by commercial and not-for-profit organizations. These organizations are normally 

subject to competitive bidding procedures. Thus, if they have been selected through competitive bidding, they 

are not subject to the $650 per day maximum compensation threshold. In those cases where an individual has 

authority to consult without employer involvement, the rate of compensation should not exceed the individual’s 

daily salary rate paid by his or her employer, subject to the $650 limitation.

To request approval of a consultant rate in excess of $650 per day, please submit the signed request on recipient

department letterhead and include the agency ORI and the award number for which the approval is being 

sought.

Please include the following:

• Description of the services to be provided by the consultant(s) or contractor(s), including

• the number of days and hours to be worked by each consultant/contractor; 

• the daily rate of each consultant/contractor that exceeds $650/day (indicate fringe benefits, if 

applicable); and

• a resume or curriculum vitae (CV) for each consultant or contracted individual whose rate exceeds $650

per day. 

• Documented prior instances when a similar rate has been charged by or paid to the consultant/contractor

• If the consultant is not self-employed and has a primary employer, documentation showing that the 

requested daily rate is proportionate to the consultant’s regular salary (e.g., pay stubs, letter from employer).

• Optional: You may submit other important information about the consultant(s) or contractor(s) at this time, 

such as letters of reference; lists of any relevant publications, papers, or honors; advanced experience as a 

practitioner or academic in the subject area; advanced training relating to the focus of your project; and/or 

any unique circumstances which you feel should be considered as the COPS Office reviews your proposed 

consultant/contractor rates.

To request approval of a consultant/contractor rate in excess of $650 per day, please return this information to 

your project manager as soon as possible to expedite the consultant/contractor rate review process. 
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Appendix G. Whistleblower protection (41 U.S.C. 4712)

41 U.S.C. § 4712. Pilot program for enhancement of contractor protection from reprisal for disclosure of 

certain information

(a) Prohibition of reprisals.--

(1) In general.--An employee of a contractor, subcontractor, or grantee may not be discharged, 

demoted, or otherwise discriminated against as a reprisal for disclosing to a person or body described in 

paragraph (2) information that the employee reasonably believes is evidence of gross mismanagement 

of a Federal contract or grant, a gross waste of Federal funds, an abuse of authority relating to a Federal 

contract or grant, a substantial and specific danger to public health or safety, or a violation of law, rule, 

or regulation related to a Federal contract (including the competition for or negotiation of a contract) or 

grant.

(2) Persons and bodies covered.--The persons and bodies described in this paragraph are the persons 

and bodies as follows:

(A) A Member of Congress or a representative of a committee of Congress.

(B) An Inspector General.

(C) The Government Accountability Office.

(D) A Federal employee responsible for contract or grant oversight or management at the relevant 

agency.

(E) An authorized official of the Department of Justice or other law enforcement agency.

(F) A court or grand jury.

(G) A management official or other employee of the contractor, subcontractor, or grantee who has 

the responsibility to investigate, discover, or address misconduct.

(3) Rules of construction.--For the purposes of paragraph (1)--

(A) an employee who initiates or provides evidence of contractor, subcontractor, or grantee 

misconduct in any judicial or administrative proceeding relating to waste, fraud, or abuse on a 

Federal contract or grant shall be deemed to have made a disclosure covered by such paragraph; 

and

(B) a reprisal described in paragraph (1) is prohibited even if it is undertaken at the request of an 

executive branch official, unless the request takes the form of a non-discretionary directive and is 

within the authority of the executive branch official making the request.

(b) Investigation of complaints.--

(1) Submission of complaint.--A person who believes that the person has been subjected to a reprisal 

prohibited by subsection (a) may submit a complaint to the Inspector General of the executive agency 

involved. Unless the Inspector General determines that the complaint is frivolous, fails to allege a 

violation of the prohibition in subsection (a), or has previously been addressed in another Federal or 

State judicial or administrative proceeding initiated by the complainant, the Inspector General shall 

investigate the complaint and, upon completion of such investigation, submit a report of the findings of 

the investigation to the person, the contractor or grantee concerned, and the head of the agency.
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(2) Inspector General action.--

(A) Determination or submission of report on findings.--Except as provided under 

subparagraph (B), the Inspector General shall make a determination that a complaint is frivolous, 

fails to allege a violation of the prohibition in subsection (a), or has previously been addressed in 

another Federal or State judicial or administrative proceeding initiated by the complainant or 

submit a report under paragraph (1) within 180 days after receiving the complaint.

(B) Extension of time.--If the Inspector General is unable to complete an investigation in time to 

submit a report within the 180-day period specified in subparagraph (A) and the person submitting 

the complaint agrees to an extension of time, the Inspector General shall submit a report under 

paragraph (1) within such additional period of time, up to 180 days, as shall be agreed upon 

between the Inspector General and the person submitting the complaint.

(3) Prohibition on disclosure.--The Inspector General may not respond to any inquiry or disclose any 

information from or about any person alleging the reprisal, except to the extent that such response or 

disclosure is--

(A) made with the consent of the person alleging the reprisal;

(B) made in accordance with the provisions of s section 552a of title 5 or as required by any other 

applicable Federal law; or

(C) necessary to conduct an investigation of the alleged reprisal.

(4) Time limitation.--A complaint may not be brought under this subsection more than three years 

after the date on which the alleged reprisal took place.

(c) Remedy and enforcement authority.--

(1) In general.--Not later than 30 days after receiving an Inspector General report pursuant to 

subsection (b), the head of the executive agency concerned shall determine whether there is sufficient 

basis to conclude that the contractor or grantee concerned has subjected the complainant to a reprisal 

prohibited by subsection (a) and shall either issue an order denying relief or shall take one or more of 

the following actions:

(A) Order the contractor or grantee to take affirmative action to abate the reprisal.

(B) Order the contractor or grantee to reinstate the person to the position that the person held 

before the reprisal, together with compensatory damages (including back pay), employment 

benefits, and other terms and conditions of employment that would apply to the person in that 

position if the reprisal had not been taken.

(C) Order the contractor or grantee to pay the complainant an amount equal to the aggregate 

amount of all costs and expenses (including attorneys’ fees and expert witnesses’ fees) that were 

reasonably incurred by the complainant for, or in connection with, bringing the complaint 

regarding the reprisal, as determined by the head of the executive agency.

(2) Exhaustion of remedies.--If the head of an executive agency issues an order denying relief under 

paragraph (1) or has not issued an order within 210 days after the submission of a complaint under 

subsection (b), or in the case of an extension of time under paragraph (b)(2)(B), not later than 30 days 

after the expiration of the extension of time, and there is no showing that such delay is due to the bad 

faith of the complainant, the complainant shall be deemed to have exhausted all administrative 
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remedies with respect to the complaint, and the complainant may bring a de novo action at law or 

equity against the contractor or grantee to seek compensatory damages and other relief available 

under this section in the appropriate district court of the United States, which shall have jurisdiction 

over such an action without regard to the amount in controversy. Such an action shall, at the request of 

either party to the action, be tried by the court with a jury. An action under this paragraph may not be 

brought more than two years after the date on which remedies are deemed to have been exhausted.

(3) Admissibility of evidence.--An Inspector General determination and an agency head order denying 

relief under paragraph (2) shall be admissible in evidence in any de novo action at law or equity brought 

pursuant to this subsection.

(4) Enforcement of orders.--Whenever a person fails to comply with an order issued under paragraph 

(1), the head of the executive agency concerned shall file an action for enforcement of such order in the 

United States district court for a district in which the reprisal was found to have occurred. In any action 

brought under this paragraph, the court may grant appropriate relief, including injunctive relief, 

compensatory and exemplary damages, and attorney fees and costs. The person upon whose behalf an 

order was issued may also file such an action or join in an action filed by the head of the executive 

agency.

(5) Judicial review.--Any person adversely affected or aggrieved by an order issued under paragraph 

(1) may obtain review of the order’s conformance with this subsection, and any regulations issued to 

carry out this section, in the United States court of appeals for a circuit in which the reprisal is alleged in 

the order to have occurred. No petition seeking such review may be filed more than 60 days after 

issuance of the order by the head of the executive agency. Review shall conform to chapter 7 of title 5. 

Filing such an appeal shall not act to stay the enforcement of the order of the head of an executive 

agency, unless a stay is specifically entered by the court.

(6) Burdens of proof.--The legal burdens of proof specified in section 1221(e) of title 5 shall be 

controlling for the purposes of any investigation conducted by an Inspector General, decision by the 

head of an executive agency, or judicial or administrative proceeding to determine whether 

discrimination prohibited under this section has occurred.

(7) Rights and remedies not waivable.--The rights and remedies provided for in this section may not 

be waived by any agreement, policy, form, or condition of employment.

(d) Notification of employees.--The head of each executive agency shall ensure that contractors, 

subcontractors, and grantees of the agency inform their employees in writing of the rights and remedies 

provided under this section, in the predominant native language of the workforce.

(e) Construction.--Nothing in this section may be construed to authorize the discharge of, demotion of, or 

discrimination against an employee for a disclosure other than a disclosure protected by subsection (a) or to 

modify or derogate from a right or remedy otherwise available to the employee.
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(f) Exceptions.— 

(1) This section shall not apply to any element of the intelligence community, as defined in section 3(4) 

of the National Security Act of 1947). (50 U.S.C. 401a(4)).

(2) This section shall not apply to any disclosure made by an employee of a contractor, subcontractor, or 

grantee of an element of the intelligence community if such disclosure—

(A) relates to an activity of an element of the intelligence community; or

(B) was discovered during contract, subcontract, or grantee services provided to an element of the 

intelligence community.

(g) Definitions. —In this section:

(1) The term “abuse of authority” means an arbitrary and capricious exercise of authority that is 

inconsistent with the mission of the executive agency concerned or the successful performance of a 

contract or grant of such agency.

(2) The term “Inspector General” means an Inspector General appointed under the Inspector General 

Act of 1978 and any Inspector General that receives funding from, or has oversight over contracts or 

grants awarded for or on behalf of, the executive agency concerned.

(h) Construction.--Nothing in this section, or the amendments made by this section, shall be construed to 

provide any rights to disclose classified information not otherwise provided by law.

(i) Duration of section.--This section shall be in effect for the four-year period beginning on the date that is 

180 days after the date the enactment of this section.
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Appendix H. 2 CFR Appendix II to Part 200: Contract provisions for 

nonfederal entity contracts under federal awards 

In addition to other provisions required by the federal agency or nonfederal entity, all contracts made by the 

nonfederal entity under the federal award must contain provisions covering the following, as applicable. 

(A) Contracts for more than the simplified acquisition threshold currently set at $150,000, which is the inflation 

adjusted amount determined by the Civilian Agency Acquisition Council and the Defense Acquisition 

Regulations Council (Councils) as authorized by 41 U.S.C. 1908, must address administrative, contractual, or legal 

remedies in instances where contractors violate or breach contract terms, and provide for such sanctions and 

penalties as appropriate.

(B) All contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal 

entity including the manner by which it will be effected and the basis for settlement.

(C) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet 

the definition of “federally assisted construction contract” in 41 CFR Part 60-1.3 must include the equal 

opportunity clause provided under 41 CFR 60-1.4(b), in accordance with Executive Order 11246, “Equal 

Employment Opportunity” (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive 

Order 11375, “Amending Executive Order 11246 Relating to Equal Employment Opportunity,” and implementing 

regulations at 41 CFR part 60, “Office of Federal Contract Compliance Programs, Equal Employment Opportunity, 

Department of Labor.”

(D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime 

construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for 

compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by Department of 

Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts Covering Federally 

Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay 

wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination 

made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a 

week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the 

Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned 

upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported 

violations to the Federal awarding agency. The contracts must also include a provision for compliance with the 

Copeland “Anti-Kickback” Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR 

Part 3, “Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans 

or Grants from the United States”). The Act provides that each contractor or subrecipient must be prohibited 

from inducing, by any means, any person employed in the construction, completion, or repair of public work, to 

give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must 

report all suspected or reported violations to the Federal awarding agency.

(E) Contract Work Hours and Safety Standards Act (40 U.S.C. 3701-3708). Where applicable, all contracts awarded 

by the non-Federal entity in excess of $100,000 that involve the employment of mechanics or laborers must 

include a provision for compliance with 40 U.S.C. 3702 and 3704, as supplemented by Department of Labor 

regulations (29 CFR Part 5). Under 40 U.S.C. 3702 of the Act, each contractor must be required to compute the 

wages of every mechanic and laborer on the basis of a standard work week of 40 hours. Work in excess of the 

standard work week is permissible provided that the worker is compensated at a rate of not less than one and a 
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half times the basic rate of pay for all hours worked in excess of 40 hours in the work week. The requirements of 

40 U.S.C. 3704 are applicable to construction work and provide that no laborer or mechanic must be required to 

work in surroundings or under working conditions which are unsanitary, hazardous or dangerous. These 

requirements do not apply to the purchases of supplies or materials or articles ordinarily available on the open 

market, or contracts for transportation or transmission of intelligence.

(F) Rights to Inventions Made Under a Contract or Agreement. If the Federal award meets the definition of 

“funding agreement” under 37 CFR §401.2 (a) and the recipient or subrecipient wishes to enter into a contract 

with a small business firm or nonprofit organization regarding the substitution of parties, assignment or 

performance of experimental, developmental, or research work under that “funding agreement,” the recipient or 

subrecipient must comply with the requirements of 37 CFR Part 401, “Rights to Inventions Made by Nonprofit 

Organizations and Small Business Firms Under Government Grants, Contracts and Cooperative Agreements,” 

and any implementing regulations issued by the awarding agency.

(G) Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal Water Pollution Control Act (33 U.S.C. 1251-1387), as 

amended—Contracts and subgrants of amounts in excess of $150,000 must contain a provision that requires the 

non-Federal award to agree to comply with all applicable standards, orders or regulations issued pursuant to the 

Clean Air Act (42 U.S.C. 7401-7671q) and the Federal Water Pollution Control Act as amended (33 U.S.C. 1251-

1387). Violations must be reported to the Federal awarding agency and the Regional Office of the Environmental 

Protection Agency (EPA).

(H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220) 

must not be made to parties listed on the governmentwide exclusions in the System for Award Management 

(SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR part 

1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM Exclusions 

contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties 

declared ineligible under statutory or regulatory authority other than Executive Order 12549.

(I) Byrd Anti-Lobbying Amendment (31 U.S.C. 1352)—Contractors that apply or bid for an award exceeding 

$100,000 must file the required certification. Each tier certifies to the tier above that it will not and has not used 

Federal appropriated funds to pay any person or organization for influencing or attempting to influence an 

officer or employee of any agency, a member of Congress, officer or employee of Congress, or an employee of a 

member of Congress in connection with obtaining any Federal contract, grant or any other award covered by 31 

U.S.C. 1352. Each tier must also disclose any lobbying with non-Federal funds that takes place in connection with 

obtaining any Federal award. Such disclosures are forwarded from tier to tier up to the non-Federal award.

(J) See §200.322 Procurement of recovered materials.
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Appendix I. Remittance of Interest Earned Amounts 

2 CFR §200.305 (b)(9) – Payment (remittance of interest earned)

1. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative 

expense. Any additional interest earned on Federal advance payments deposited in interest-bearing 

accounts must be remitted annually to the Department of Health and Human Services Payment 

Management System (PMS) through an electronic medium using either Automated Clearing House (ACH) 

network or a Fedwire Funds Service payment. Remittances must include pertinent information of the payee 

and nature of payment in the memo area (often referred to as “addenda records” by Financial Institutions) as 

that will assist in the timely posting of interest earned on federal funds. Pertinent details include the Payee 

Account Number (PAN) if the payment originated from PMS, or Agency information if the payment 

originated from ASAP, NSF or another federal agency payment system. The remittance must be submitted as 

follows:

i. For ACH Returns:

Routing Number: 051036706

Account number: 303000

Bank Name and Location: Credit Gateway - ACH Receiver St. Paul, MN

ii. For Fedwire Returns*:

Routing Number: 021030004

Account number: 75010501

Bank Name and Location: Federal Reserve Bank Treas NYC/Funds Transfer Division New York, NY

(* Please note organization initiating payment is likely to incur a charge from your Financial Institution for this 

type of payment)

iii. For International ACH Returns:

Beneficiary Account: Federal Reserve Bank of New York/ITS (FRBNY/ITS)

Bank: Citibank N.A. (New York)

Swift Code: CITIUS33

Account Number: 36838868

Bank Address: 388 Greenwich Street, New York, NY 10013 USA

Payment Details (Line 70): Agency

Name (abbreviated when possible) and ALC Agency POC: Michelle Haney, (301) 492-5065

iv. For recipients that do not have electronic remittance capability, please make check** payable to: 

“The Department of Health and Human Services.”

Mail Check to Treasury approved lockbox:

HHS Program Support Center, P.O. Box 530231, Atlanta, GA 30353-0231

(** Please allow 4-6 weeks for processing of a payment by check to be applied to the appropriate PMS account)

v. Any additional information/instructions may be found on the PMS Web site 

at http://www.dpm.psc.gov/. 
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Glossary of Terms

allowable costs. Allowable costs are expenses that may be funded by this award program. The COPS Office CPD 

award must be limited to funding for equipment, services, personnel, and other costs purchased or hired on or 

after the award start date. Upon review of your submitted budget, any unallowable costs were removed. The 

Financial Clearance Memorandum (FCM) included in your award package specifies your allowable costs, 

contains the final budget category amounts for which your agency was approved, and notes any relevant 

revisions that were made to your original budget submission.

audit. Work done by auditors, including both the Office of the Inspector General (OIG) and state or local 

auditors, to examine financial statements and to review 

• compliance with laws and regulations; 

• economy and efficiency of operations; 

• effectiveness in achieving program results; 

• allowability of costs claimed against the award.

authorized officials. The authorized officials are the individuals in your organization who have final authority 

and responsibility for all programmatic and financial decisions regarding this award. At the time of award 

application, your agency listed the law enforcement executive (usually the chief of police, sheriff, etc.) and the 

government executive (usually the mayor, board president, etc.) for your agency. For non-law enforcement 

agencies (institutions of higher education, private organizations, etc.), the authorized officials are the 

programmatic and financial officials who have the ultimate signatory authority to sign contracts on behalf of 

your organization. These executives are listed on your award document and are understood to be your 

authorized officials. If any of the executive information is incorrect, please submit the correct information to the 

COPS Office by completing an official Change of Information form available online at www.cops.usdoj.gov. 

award number. The award number identifies your agency’s specific Community Policing Development award 

and can be found on your award document. This number should be used as a reference when corresponding 

with the COPS Office. Your award number is in the format 2016-CKWX-0000 for awards made in FY 2016. The 

COPS Office tracks award information based upon this number.

award start date. This is the date on or after which your agency is authorized to purchase or hire any allowable 

equipment, services, personnel, or other costs that were approved by the COPS Office. The award start date is 

found on your award document. Recipients may not expend funds prior to this date without written approval 

from the COPS Office. 

career law enforcement officer. The COPS Office statute defines a career law enforcement officer as a person 

hired on a permanent basis who is authorized by law, or by a state or local public agency, to engage in or 

oversee the prevention, detection, or investigation of violations of criminal laws.

Catalog of Federal Domestic Assistance (CFDA). The CFDA is an annual government-wide publication that 

contains a description and index of all forms of federal assistance. Each program is assigned a CFDA number, 

which is used by auditors to track award revenues under the Single Audit Act. It is also used in participating 

states by State Single Points of Contact in conducting the required intergovernmental reviews under Executive 

Order 12372. The CFDA number for the COPS Office CPD Program award is 16.710.
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closeout. This is the process in which the awarding agency, the COPS Office, determines that all applicable 

administrative actions and all required work and conditions of the award have been completed and met by the 

recipient and awarding agency.

cognizant federal agency. Your cognizant federal agency is generally the federal agency that provides your 

agency with the most federal money. The Office of Management and Budget (OMB) may have already assigned 

your cognizant federal agency to you. If this is the first federal award that your organization has received, the 

U.S. Department of Justice (DOJ) is your cognizant federal agency. 

community policing. Community policing is a philosophy that promotes organizational strategies that support 

the systematic use of partnerships and problem-solving techniques to proactively address the immediate 

conditions that give rise to public safety issues such as crime, social disorder, and fear of crime. All newly hired, 

additional, or rehired officers (or an equal number of redeployed veteran officers) funded under COPS Office

programs must engage in community policing activities.

Computer Aided Dispatch (CAD) system. A computer database that can track calls for service, maintain status 

of units available, provide various reports, produce address histories, and support electronic mail. With the 

installation of integrated CAD systems, officers are able to receive calls for service on their mobile data 

computers rather than over the radio. Radios can then be used only for serious emergencies. 

consortium. A consortium is a group of two or more governmental entities that agree to form a partnership to 

provide law enforcement services to their constituent communities. 

COPS Office Finance Staff. The COPS Office finance staff handles your agency’s financial and budgetary needs 

related to this award. A staff accountant has been assigned to your state, and is available to answer any 

questions that you may have concerning the financial aspects of your award. To identify your staff accountant, 

please call the COPS Office Response Center at 800-421-6770, or visit the COPS Office website at 

www.cops.usdoj.gov.

COPS Office. The Office of Community Oriented Policing Services (COPS Office) is the division within the U.S. 

Department of Justice that is the grantor agency for your award. The COPS Office is responsible for assisting your 

agency with the administration and maintenance of your award for the entire award period. You can reach the

COPS Office at 800-421-6770.

COPS Office Program Manager. COPS Office Program Managers are trained to assist you with implementing 

and maintaining your Community Policing Development award. A program manager is assigned to your project 

and is available to answer any questions that you may have concerning the administrative, programmatic, and 

substantive aspects of your award. Your program manager can assist you with such matters as requesting an 

extension on your award or modifying the award, and reviewing outlines for project deliverables. The name and 

phone number of your COPS Office Program Manager is provided on the award congratulatory letter and 

available by contacting the COPS Office Response Center at 800-421-6770.

Data Universal Numbering System (DUNS) number. Since FY 2004, the Office of Management and Budget 

(OMB) has required all agencies applying for federal funding to obtain this number prior to application. The 

DUNS number is a unique nine- or thirteen-digit identification number that is assigned upon request to agencies 

by Dun & Bradstreet (D&B). This number will be used by the Federal Government to better track award recipient 
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information throughout the award cycle and to provide consistent name and address data for electronic award

application systems. To obtain a DUNS number, visit the Dun & Bradstreet website at www.dnb.com or call 866-

705-5711.

Employer Identification Number (EIN) / OJP vendor number. This number is usually your agency’s nine-digit 

federal tax identification number as assigned to you by the Internal Revenue Service (IRS). Your 

accounting/bookkeeping department should have this number. In some cases, the EIN has been previously 

assigned to another agency within your jurisdiction. In this instance, a new vendor number will be assigned to 

you by the Office of the Chief Financial Officer. The newly assigned number is to be used for COPS Office

administrative purposes only and should not be used for IRS purposes.

federally recognized tribe. Tribal entities that are recognized and eligible for funding and services from the BIA 

by virtue of their status as Indian tribes. They are acknowledged to have the immunities and privileges available 

to other federally recognized Indian tribes by virtue of their government-to-government relationship with the 

United States as well as the responsibilities, power, limitations, and obligations of such tribes. Only federally 

recognized tribes are eligible to apply for COPS Office tribal award funds. For further information, contact BIA, 

Division of Tribal Government Services, MS-4631 – MIB, 1849 C Street NW, Washington, DC 20240, 202-208-2475. 

Grant Monitoring Specialist. COPS Office Grant Monitoring Specialists are trained and available to assist you in 

addressing any compliance-related questions regarding your award. Grant monitoring specialists plan and 

conduct site visits and office-based grant reviews. During the life of your award, you may be selected for a 

monitoring site visit to assess your compliance with the terms and agreements of the award program, to review 

your community policing initiatives, and to provide technical and administrative support for your award. Please 

contact the COPS Office Response Center at 800-421-6770 if you have any compliance-related questions.

local budget cycle. Your agency’s fiscal year. Some common examples include January 1 to December 31, 

October 1 to September 30, and July 1 to June 30. Some local budget cycles may extend up to 24 months. 

obligation of funds. The COPS Office obligates federal funds when the award document is signed by the COPS 

Office Director or his or her designated official. For the recipient, award funds are obligated when monies are 

spent or orders are placed for purchasing approved technology or services under your Community Policing 

Development award. The term “encumbrance” is often used at the local and state levels to describe this type of 

transaction. Liquidated obligations are considered cash outlays or monies actually spent. Unliquidated 

obligations are obligations incurred and recorded but not yet paid (accrual basis of accounting) or not yet 

recorded and not yet paid (cash basis of accounting).

Originating Agency Identifier (ORI) number. This number is assigned by the FBI, and it is your agency’s unique 

identifier. The first two letters are your state abbreviation, the next three numbers are your county’s code, and 

the final two numbers identify your jurisdiction within your county. If your agency does not have an ORI number 

assigned by the FBI, the COPS Office assigns a non-official ORI code to use as an agency identifier (in such cases, 

the last two characters will be “ZZ”). It can be found on your award document. When you contact the COPS 

Office with a question, please reference your ORI number (or your award number). 

primary law enforcement authority. An agency with primary law enforcement authority is the agency that is 

the first responder to calls for service, and has ultimate and final responsibility for the prevention, detection, or 

investigation of violations of criminal laws within its jurisdiction.
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The Public Safety Partnership and Community Policing Act of 1994. The COPS Office is charged with 

fulfilling the mandates of this law. The purposes of the law are to

• increase the number of community policing officers on the beat;

• provide additional and more effective training to law enforcement officers to enhance their problemsolving, service, and other skills needed in interacting with members of the community;

• encourage the development and implementation of innovative programs to permit members of the 

community to assist law enforcement agencies in the prevention of crime;

• encourage the development of new technologies to assist law enforcement agencies in reorienting the 

emphasis of their activities from reacting to crime to preventing crime.

SAFECOM guidance

The U.S. Department of Homeland Security Office of Emergency Communications, in coordination with various 

stakeholder groups, develops the annual SAFECOM Guidance on Emergency Communications Grants. The 

guidance provides recommendations to recipients seeking funding for interoperable emergency 

communications projects, including allowable costs, items to consider when funding emergency 

communications projects, awards management best practices for emergency communications awards, and 

information on standards that ensure greater interoperability. The guidance is intended to ensure that federally 

funded investments are compatible and support national goals and objectives for improving interoperability 

nationwide. Recipients (including sub-recipients) that are using CPD funds to support emergency 

communications activities should comply with the latest version of SAFECOM Guidance, including provisions on 

technical standards that ensure and enhance interoperable communications. The most recent version of 

SAFECOM guidance is available at www.safecomprogram.gov/grant/Default.aspx. 

System for Award Management (SAM). The SAM database is the repository for standard information about 

federal financial assistance applicants, recipients, and sub-recipients. Organizations that have previously 

submitted applications via Grants.gov are already registered with SAM, as it is a requirement for Grants.gov

registration. Please note, however, that applicants must update or renew their SAM at least once per year to 

maintain an active status. Information about registration procedures can be accessed at www.sam.gov. 

supplanting. For the purposes of your COPS Office Community Policing Development award, supplanting 

means replacing state, local, or Bureau of Indian Affairs (BIA) funds that otherwise would have been spent on 

award purposes with federal COPS Office funds. State, local, and tribal governments are prohibited from 

supplanting throughout the award period. This means that your agency may not use COPS Office funds to pay 

for any equipment/technology, services, personnel, or other items which, in the absence of the COPS Office

program, would otherwise have been funded with state or local funds or with funds supplied by the BIA. The 

COPS Office funds must instead be used to supplement, or increase, your budget on award purposes. For 

additional information on supplanting, please review award condition #4 on page 8 in this manual.
2016 COPS Office Community Policing Development 

(CPD) Program Award Owner’s Manual

This manual was created to assist COPS Office Community Policing Development (CPD) program recipients with 

the administrative and financial matters associated with their award.

For more information about your CHP award, please contact your COPS Office Grant Program Specialist. If you 

do not know the name or telephone number of your Grant Program Specialist, please contact the COPS Office 

Response Center at 800-421-6770.

U.S. Department of Justice

Office of Community Oriented Policing Services

145 N Street NE

Washington, DC 20530

To obtain details about COPS Office programs, call the COPS Office Response Center at 800-421-6770.

Visit the COPS Office online at www.cops.usdoj.gov. 

Published September 2016